Part 2 Calculation of Profits of MSCs: Deduction for Deemed Employment Payments

Part 2 Calculation of Profits of MSCs: Deduction for Deemed Employment Payments

Deduction for deemed employment payments for income tax purposes

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In ITTOIA 2005, after section 164 insert—

“Managed service companies
164A Deduction for deemed employment payments

(1)     This section applies for the purpose of calculating the profits of a trade, profession or vocation carried on by a managed service company (“the MSCâ€) which is treated as making a deemed employment payment in connection with the trade, profession or vocation.

(2)     A deduction is allowed for—

(a)     the amount of the deemed employment payment, and

(b)

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