A company has had taxable profits exceeding £1.5M and a corporation tax liability exceeding £10K for a number of years. It expects to have taxable profits for the current year of £1M and a tax liability exceeding £10K. Does section 3(3)(b) of The Corporation Tax (Instalment Payments) Regulations 1998 mean that the company must still make payments on account for the current year on the basis that it was considered large for the previous year?
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Section 3 starts by saying a company is not large if...., but the opposite does not apply, so if it is not over £1.5m profits it is not large (Section 1) and this is not overridden by Section 3, as this section does not say a company is not large ONLY if.... , it just gives an exclusion from being large if (a) or (b) apply.
So you are OK being non-large as soon as the profits drop below £1.5m.
Come on, Jack.
If you're acting for a company big enough to make QUIPs, you must have the nouse and intelligence to look straightforward things like this up in Tolleys.
If not, that's pretty scary.