Corporation Tax Act 2009 section 174

Restrictions on relief

Section 174 sets out the circumstances in which a company cannot claim a deduction for unremittable amounts under the trading income provisions.

• No deduction is available where the unremittable amount has been used to fund expenditure, investment, or any other application outside the United Kingdom.
• No deduction is available to the extent that an insurance payment has been received in respect of the amount owed.
• No deduction is available where the company can instead claim relief for unremittable income under Part 18 of the Act, which applies where trading profits including the unremittable amounts arise outside the United Kingdom (for example, through an overseas branch).
• These restrictions ensure that relief is only given once and only where the funds are genuinely trapped, rather than applied elsewhere or already compensated through insurance or alternative relief claims.