CFM95840 - Interest restriction: tax-EBITDA: Charitable Donations Relief
TIOPA10/S407(3)(k)
Deductions for qualifying charitable donations, under CTA10/S189, are excluded from the calculation of adjusted corporation tax earnings when determining a company바카라 사이트™s tax-EBITDA.
Qualifying charitable donations made by a company are allowed as deductions from the company바카라 사이트™s total profits in calculating the corporation tax chargeable for an accounting period.
Being deducted from the company바카라 사이트™s total profits after any other relief from corporation tax other than group relief, the amount of charitable donations relief available is limited to the amount that reduces the company바카라 사이트™s total taxable profits to nil.
Further guidance on charitable donations relief can be found at CTM09000.
Effect for tax-EBITDA purposes
Charitable donations relief is one of the qualifying tax reliefs specified as an excluded amount in TIOPA10/S407(3).
Any deductions received for qualifying charitable donations would have the effect of reducing the earned profit of the company for tax-EBITDA purposes, reducing the amount of interest it can deduct.
Consequently, deductions received for qualifying charitable donations under CTA10/S189 should not be brought into account when calculating taxable total profits of the period to determine a company바카라 사이트™s tax-EBITDA