Section 257 Transfer involving person within the charge to income tax

(1)

This section explains how section 255 works if—

(a)

the transferor is a company within the charge to corporation tax and the transferee is a person within the charge to income tax, or

(b)

the transferor is a person within the charge to income tax and the transferee is a company within the charge to corporation tax.

(2)

Section 255 applies only for the purpose of determining—

(a)

whether the company within the charge to corporation tax is entitled to a deduction (or part of a deduction) under section 254, and

(b)

the amount of any such deduction.

(3)

Accordingly, any reference to—

(a)

whether a person is entitled to a deduction (or part of a deduction) under section 254, or

(b)

the amount of any such deduction,

is ignored if the person is within the charge to income tax.

(4)

For any entitlement of a person within the charge to income tax to a deduction for any of the expenditure, see sections 316 to 318 of ITTOIA 2005 (corresponding income tax provisions).