Corporation Tax Act 2010 section 952

Apportionment if part of trade treated as separate trade

Section 952 deals with how receipts, expenses, assets and liabilities should be divided up when part of a trade is treated as a separate trade under section 951.

• Where part of a trade is treated as a separate trade under section 951, all receipts, expenses, assets and liabilities must be apportioned on a just and reasonable basis.
• This apportionment process applies whenever the separation of a trade into distinct parts triggers the need to allocate financial items between those parts.
• If the apportionment is material to the tax liability of two or more companies and a disagreement arises about how it should be made, the dispute is resolved through a process equivalent to an appeal.
• All companies affected by the apportionment are entitled to be a party to the proceedings in which the dispute is determined.