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Historical intended purpose FA 1991 Sch 11 Para 4

Circumstances when a Building Society might have been able to claim twice for the same deduction.

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Trying to understand piece of legislation for academic purposes.

It's not a matter of not being bothered or not being willing to apply effort-there just isn't that much to this.  Position is-
-I read Tolleys Corporation Tax book.
-Didn't see why this provision was incorporated.
-Asked Tolleys but they wouldn't help.
-Asked CIOT but they couldn't help.
-Asked HMRC but they wouldn't help.
Am simply trying to understand this for academic purposes.  That's all there is to it.

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18th Jan 2019 17:22

Thanks for letting us know.

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18th Jan 2019 17:38

If you can't be bothered to put some meat on the bones, don't expect any help.

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By SXGuy
19th Jan 2019 09:38

Given the lack of effort in writing a question I can see why the help is needed.

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By Kylie
19th Jan 2019 13:21

.

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to Kylie
19th Jan 2019 13:28

Kylie

Even in the post you deleted, you couldn't be bothered to say what you didn't understand.

What help can you possibly expect ? An essay on an obscure piece of legislation relating to Building Societies ?

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19th Jan 2019 15:24

I doubt you'll get much traction in here on a piece of legislation no contributors to these discussions would have noticed arriving, none noticed go and none cared about for the years it was in force.

For what it's worth, I suspect you are overthinking. My guess would be that relief could have been claimed more than once for the same deduction if there wasn't a rule that said otherwise. You have found the rule that said otherwise and read gunpowder treason and plot into its mere existence.

Do you know there are lots of similar rules? Is your academic piece discussing the different modi operandi of such rules?

A good comparison is afforded by the rules preventing double relief for a loss. For income tax, there's a separate rule in s63 ITA 2007. For corporation tax, double relief under Ss37 and 42 is inherently prevented by the way those reliefs work; additional relief by carry-forward is stopped by s45(3).

Good luck with your piece.

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