Introduction Overview Overview Section 874: Charge to corporation tax
2593.This section imposes the charge to corporation tax on the company obtaining the capital sum. It is based on sections 781(1), (1B), (2) and (6) of ICTA.
2594.Under subsection (1), there is a charge to corporation tax on income for the accounting period in which the sum is obtained.
2595.Subsection (2) measures the amount on which tax is charged.
2596.Subsection (3) introduces four subsections limiting the effect of subsections (1) and (2).
2597.Subsection (4) caps the amount on which tax is charged.
2598.To prevent double taxation, subsections (5) and (6) ensure that once a payment (or part of a payment) has been taken into account in making a charge under this section it cannot be taken into account in making a further charge in respect of another sum.
2599.Subsection (7) is a timing rule supplementing subsections (5) and (6).