Income Tax Act 2007

Memorandum accounts - Imputation credit accounts (ICA)

OB 46: ICA transfer from member fund

You could also call this:

"Transferring money from a company to a master fund and how tax works"

Illustration for Income Tax Act 2007

When a company transfers expenditure to a master fund, it gets an imputation debit. You calculate this debit by multiplying the expenditure transferred by the tax rate. The tax rate is the basic rate of income tax, which you can find in schedule 1, part A, clause 2. The imputation debit is recorded on the last day of the tax year. You can find more information about this debit in table O2: imputation debits, row 19. The expenditure transferred is the amount transferred under sections DV 5 to DV 7.

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OB 45: ICA redemption debit, or

"Debit for cancelling units in a managed fund"


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OB 46B: ICA transfer from group company to loss-using group company, or

"Transfer of tax credits between companies in the same group when one is using a loss"

Part OMemorandum accounts
Imputation credit accounts (ICA)

OB 46ICA transfer from member fund

  1. An ICA company has an imputation debit for an amount calculated using the formula—

    expenditure transferred × tax rate.

    Where:

    • In the formula,—

    • expenditure transferred is the amount of expenditure transferred under sections DV 5 to DV 7 (which relate to expenditure related to investment funds) by the company, as a member fund, to a master fund:
      1. tax rate is the basic rate of income tax set out in schedule 1, part A, clause 2 (Basic tax rates: income tax, ESCT, RSCT, RWT, and attributed fringe benefits).
        1. The imputation debit in subsection (1) is referred to in table O2: imputation debits, row 19 (transfer from member fund).

        2. The debit date is the last day of the tax year corresponding to the income year in which the expenditure is deducted.

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        Notes
        • Section OB 46(2)(b): amended, on , by section 562 of the Taxation (Business Taxation and Remedial Matters) Act 2007 (2007 No 109).
        • Section OB 46 list of defined terms basic rate: repealed, on , by section 243 of the Taxation (Annual Rates for 2015–16, Research and Development, and Remedial Matters) Act 2016 (2016 No 1).