Community Amateur Sports Clubs

Income test - meaning of 'receipts'

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Club currently meets all CASC conditions. However, it is considering the transfer of land held as development stock to its 100% trading subsidiary. Land is currently worth £5m, with a similar base cost, so there should be little or no actual profit on the transfer. However, what if the consideration for the sale is £1? We've covered off the VAT and SDLT issues, so need to consider those, thanks. s661CA of CTA 2010 refers to the receipts brought into account in computing trade profits in the context of the £100k limit. What exactly is meant by 'receipts'? In absence of any definition to the contrary, I would argue that it means what it says - amounts actually received, rather than any amount deemed to have been received for tax purposes (and, for example, s167 of CTA 2009 makes a specific distinnction between the tax value and amount actually realised).

Thoughts, anyone? With thanks in advance.

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