Annex 1: Minor Changes in the Law Change 77: Additional relief for research and development: applies for corporation tax only: sections 1044, 1045, 1063, 1068, 1074, 1087, 1092 and 1149 Contaminated land
The change that additional relief is available only to companies liable to corporation tax also applies to the additional relief that is available under section 1149 for expenditure on the remediation of contaminated land.
Paragraph 13 of Schedule 22 to FA 2001 provides that a company may deduct 150% of its qualifying land remediation expenditure from the profits of a Schedule A business or a trade carried on by the company. This paragraph does not limit the relief to corporation tax, but should only apply to corporation tax for the same reasons as those mentioned above for research and development. The change makes it clear that the additional relief applies only for corporation tax.
This change removes the possibility of entitlement to relief for companies subject to income tax.
This change is adverse to some taxpayers in principle. But it is expected to have no practical effect as it is in line with generally accepted practice.