{
  "url": "https://openlegislation.uk/corporation-tax-act-2010/section-177",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2010/section-177.json",
  "legislation": "ukpga/2010/4",
  "legislation_title": "Corporation Tax Act 2010",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2010",
  "path": "section/177",
  "kind": "section",
  "number": "177",
  "heading": "Cases in which both sections 172 and 174 apply",
  "text": "(1) This section applies in a case in which sections 172 and 174 apply but section 170 does not.\n(2) Determine what company A's proportion would be—\n(a) on the basis mentioned in section 172(1),\n(b) on the basis mentioned at Step 4 in section 174,\n(c) on those bases taken together, and\n(d) ignoring sections 172 and 174.\n(3) Company A's proportion is taken to be the lowest proportion determined under subsection (2).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "C",
      "label": "C1",
      "text": "Ss. 169-178 applied (with modifications) (24.2.2022) by Finance Act 2022 (c. 3), Sch. 2 para. 5(4) (as amended (11.7.2023) by Finance (No. 2) Act 2023 (c. 30), Sch. 4 para. 10)"
    },
    {
      "type": "C",
      "label": "C2",
      "text": "Pt. 5 Ch. 6 applied in part (with effect in accordance with s. 51 of the amending Act) by Finance Act 2022 (c. 3), s. 50(2)(3)"
    },
    {
      "type": "C",
      "label": "C3",
      "text": "Pt. 5 Ch. 6 applied (temp.) (with effect in accordance with Sch. 10 para. 43 of the amending Act) by Finance Act 2022 (c. 3), Sch. 10 para. 6(2) (as amended (5.1.2023) by The Finance Act 2022, Schedule 10 (Public Interest Business Protection Tax) (Substitution of Date) Regulations 2022 (S.I. 2022/1321), regs. 1, 2(2))"
    },
    {
      "type": "C",
      "label": "C4",
      "text": "Pt. 5 applied (with modifications) (24.2.2022) by Finance Act 2022 (c. 3), Sch. 2 para. 47(4)"
    },
    {
      "type": "C",
      "label": "C5",
      "text": "S. 177(3) applied (with modifications) (temp.) (with effect in accordance with Sch. 10 para. 43 of the amending Act) by Finance Act 2022 (c. 3), Sch. 10 para. 6(3)(c) (as amended (5.1.2023) by The Finance Act 2022, Schedule 10 (Public Interest Business Protection Tax) (Substitution of Date) Regulations 2022 (S.I. 2022/1321), regs. 1, 2(2))"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/4/section/177",
    "retrieved_at": "2026-10-29T09:10:29.433154+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}