Commentary

D7.536 Sundry receipts

Corporate tax
Corporate tax | Commentary

D7.536 Sundry receipts

Corporate tax | Commentary

D7.536 Sundry receipts

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

The I-E basis of assessment operates on the principle that while an insurance company's income and gains are capable of being assessed as trading receipts, alternative heads of charge exist for the company's income and gains from the disposal of investments are capable of being taxed according to the capital gains tax rules. As a corollary, if there is no head of charge other than CTA 2009, s 35 for certain items of income, such as share underwriting commission received, refunds of commission paid and management fees from subsidiary companies, those items would escape tax if the company is assessed on the I-E basis. To counter

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