These notes refer to the Corporation Tax Act 2010 (c.4) which received Royal Assent on 3 March 2010 CORPORATION TAX ACT 2010 EXPLANATORY NOTES These explanatory notes relate to the Corporation Tax Act 2010 which received Royal Assent on 3 March 2010. They have been prepared by the Tax Law Rewrite project at HMRC to assist readers in understanding the Act. They do not form part of the Act and have not been endorsed by Parliament. The notes need to be read in conjunction with the Act. They are not, and are not meant to be, a comprehensive description of its contents. So if a section or part of a section does not seem to require explanation or comment, none is given. The commentary on each section indicates the main origin or origins of the section. A full statement of the origins of each section is contained in the Act's Table of Origins. At the end of the commentary, there is supporting material in two annexes: Annex 1 contains details of the minor changes in the law made by the Act; Annex 2 contains lists of: the Extra-Statutory Concessions to which the Act gives effect, the minor changes made by the Act which involve giving statutory effect to principles derived from case law, and provisions not included in the Act on the grounds of redundancy. Summary The main purpose of the Corporation Tax Act is to rewrite primary corporation tax legislation so that it is clearer and easier to use but without changing its general effect. This Act contains provisions which affect the calculation of liability such as losses and group relief. It also contains provisions dealing with distributions, avoidance and particular types of companies and activities. The Act reproduces the law on which it is based. It does not generally change the meaning of the law. The minor changes which it does make are within the remit of the Tax Law Rewrite project and the Parliamentary process for the Act. In the main, such minor changes are intended to clarify existing provisions, make them consistent or bring the law into line with well established practice.