FLK1 · Business Law & Practice

Corporation tax

SQE1 revision notes — the key rules, leading cases and common traps for this topic, in plain English and current to 2026.

BLP.15 — Corporation Tax

What it is. Corporation tax (CT) is charged on a UK company's taxable total profits (TTP) for an accounting period — its income profits plus chargeable gains. Companies do not pay income tax or CGT; they pay CT on both streams. Governing statute: CTA 2009 (charge/income), CTA 2010 (rates/reliefs), TCGA 1992 (gains computation). The company is liable, files a CT600, and self-assesses.

The rates (FY2026/27)

  • 19% small-profits rate — profits ≤ £50,000.
  • 25% main rate — profits > £250,000.
  • Marginal relief smooths the band £50,000–£250,000 (effective marginal rate ~26.5%).
  • Thresholds are divided by the number of associated companies and time-apportioned for short periods. Watch this trap.

Calculating TTP

  1. Income profits = trading receipts less deductible expenses (wholly & exclusively for trade) and capital allowances. Two distinct 100% reliefs to keep apart:
    • Annual Investment Allowance (AIA) — 100% deduction on qualifying plant & machinery (new or second-hand), capped at £1m per year.
    • Full expensing — a separate 100% first-year allowance on new/unused main-rate plant & machinery, with no monetary cap (permanent from 1 Apr 2023; 50% FYA for special-rate pool assets).
    • Otherwise, writing-down allowances: 18% (main pool) / 6% (special rate pool).
  2. Chargeable gains = proceeds − allowable costs − indexation allowance frozen at Dec 2017 (companies still get indexation up to that date; individuals get none).
  3. Add income profits + gains = TTP; apply the rate.

Loss relief (key distinctions)

  • Trading losses: set against total profits of the same period, then carry back 12 months, or carry forward against future total profits (post-1 Apr 2017 losses are flexible but subject to the £5m + 50% restriction).
  • Capital losses: relievable only against chargeable gains, never income.

Common traps to nail

  • Don't apply income tax/CGT rates to a company — only CT applies, and it taxes gains too.
  • Associated companies reduce the £50k/£250k thresholds — a single shareholder's group can lose the small-profits rate.
  • AIA (£1m cap) ≠ full expensing (no cap) — don't merge them; full expensing is new main-rate plant only.
  • Dividends paid are NOT deductible (paid from post-tax profit); dividends received are usually exempt.
  • Indexation: companies yes (to Dec 2017), individuals no.
  • Payment timing: small companies pay 9 months + 1 day after period end; large companies pay by quarterly instalments.
  • VAT (£90,000 registration threshold) is separate from CT — don't conflate.

More Business Law & Practice topics

See all topics in the FLK1 guide or the full SQE1 syllabus.

Independent SQE1 revision notes for study — not legal advice; check primary sources before relying on any point. Exam rules are set by the SRA; see the official SQE site.