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Chapter BKM403850

Document Cited authorities 1 Cited in Related
Vincent
Published date19 July 2017
Record NumberBKM403850
CTA10/S269DD

TCGA92/S170 defines a group of companies for capital gains purposes. The rules at TCGA92/S171A allows for the transfer of part or all of a chargeable gain or chargeable loss between companies in the same group.

The banking surcharge is charged on a banking company’s taxable total profits with certain adjustments (BKM403100). A banking company’s surcharge profits should include all the chargeable gains which arose to that company in the chargeable accounting period but should not include any chargeable gains which arose to a non-banking company. Where chargeable gains arising in a chargeable accounting period have been transferred between a banking and a non-banking company under s171A, adjustments are needed to arrive at the surcharge profits.

A banking company’s taxable total profit for a chargeable accounting period will not include any chargeable gains which arose in that period and were transferred from that company to a non-banking company under a section 171A election. Without the election these chargeable gains would be subject to the surcharge. The surcharge legislation requires an adjustment to be made to add the total of these relevant transferred-out gains to the taxable total profits for the chargeable accounting period (CTA10/S269DD para 2(a)).

A banking company’s taxable total profit for a chargeable accounting period will include any chargeable gains...

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