Corporation Tax Act 2009 section 931W

Provisions which must be given priority over this Part

Section 931W establishes that certain other parts of the Corporation Tax Act take precedence over Part 9A when income could potentially fall under more than one charging provision.

  • Where distribution income also qualifies as trade profits under Part 3, it must be taxed under Part 3 rather than Part 9A
  • Where distribution income also qualifies as UK property business profits under Part 4, it must be taxed under Part 4 rather than Part 9A
  • Part 9A only applies to distributions that are not already taxed under these alternative provisions
  • The priority rules prevent the same income from being subject to overlapping tax charges

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