Commentary

D7.496 Transition—excluded items

Corporate tax
Corporate tax | Commentary

D7.496 Transition—excluded items

Corporate tax | Commentary

D7.496 Transition—excluded items

It is not sufficient however simply to identify the individual component parts (called 'relevant computational items') making up the total transitional difference, they must also be analysed to identify any that should be excluded because it is not appropriate to tax or relieve them as the case may be1.

The legislation identifies four types of excluded items:

  1.  

    (1)     deferred acquisition costs included in the closing 2012 balance sheet and which have already been relieved under the pre-2013 regime

  2.  

    (2)     the value of future profits arising from a business transfer (but not if the asset is treated as internally

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