Getting colder

My article Cold comfort for corporates has attracted a couple of comments in Feedback.

Marion (in More cold comfort) questioned whether the small profit rate can still be claimed even if the conditions in CTA 2010 s 26 are not fully met.

As the article made clear a holding company can if certain stringent conditions are met be treated as a non-active company (i.e. not carrying on any trade or business) for the purposes of the small profits relief.

However this relieving provision only applies – at least in my view – if the company would otherwise be regarded as active.

If the company for whatever reason (perhaps a few pounds in its bank account) does not satisfy those stringent conditions I feel it...