INTM601140 - Transfer of assets abroad: The income charge: Measure of income - investment companies

The income of companies with investment business (‘investment companies’) can include a variety of sources and it is the effect of applying UK tax codes to each particular source that determines which, if any, deductions are to be made in arriving at the amount of the income charge.

Expenses of management of a company’s investment business are allowed as a deduction from the company’s total profits (CTA09/S1219) rather than from particular sources of income. No deduction for expenses of management of a company’s investment business is therefore made in arriving at the amount of the income charge (see Lord Chetwode v CIR, 51 TC 647).