Commentary

D7.4102 Period over which receipts or expenses arise

Corporate tax
Corporate tax | Commentary

D7.4102 Period over which receipts or expenses arise

Corporate tax | Commentary

D7.4102 Period over which receipts or expenses arise

Receipts or expenses allocated to BLAGAB and non-BLAGAB business as the case may be are spread over the ten-year period beginning on 1 January 20131.

The amount apportioned to any accounting period falling within that ten-year period is apportioned by reference to the number of days of the accounting period within the longer ten-year period2.

The general rule does not however apply to receipts arising from relevant court-protected items and is also subject to, and possibility over-ridden by, the rules dealing with transfers and cessations of business3.

Receipts arising from relevant court-protected items are treated as arising over the ten-year period beginning with the relevant day which is defined as the earlier of 1 January 2015 or the day on which the court imposed restraint ceases to exist4. As a result most such relevant computational items benefit from a further three-year period before they fall into tax after which they too are subject to a ten-year spread although the general rule is also

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