CTM90105 - CTSA: introduction: background

CTSA applies to companies for accounting periods ended on or after 1 July 1999.

CTSA imported the finality and enquiry rules of SA into the general administrative framework for corporation tax purposes.

It also brought into a single SA:

  • tax chargeable under CTA10/S455 on loans or advances by close companies to participators,
  • tax that was chargeable under ICTA88/S747 on the profits of controlled foreign companies for accounting periods ending on or before 31 December 2012.

You should read references in this guidance to ‘tax� and to ‘CT� accordingly, where the context requires.