IHTM04192 - Dispositions allowable for income tax or conferring retirement benefits: deductions allowable for income tax
Under IHTA84/S12 (1) a disposition (IHTM04023) by any person is not a transfer of value (IHTM04024) if it
- is allowable in computing that person’s profits or gains for income tax or corporation tax purposes,
- would be so allowable if those profits or gains were sufficient to be so computed.
An example is a Christmas bonus paid to employees.
A person (IHTM04052) includes a company. So the subsection expressly covers a disposition by a company, etc which is deductible for corporation tax, including, for example
- amounts deductible from taxable rents,
- management expenses of an investment company, and
- payments deductible from trading, etc profits.
»Ê¹ÚÌåÓýapp subsection does not, however, apply to dispositions deductible against profits, etc which are not within the charge to United Kingdom income tax or corporation tax.