Various cases have established the tax treatment of a bank's income. Items that may not be income for other companies are included in the profit calculation for banks, due to the nature of their trade. Specific items are discussed below but the general underlying principle that a charge to corporation tax is imposed on the profits of a trade is (as it is for all trading companies) the starting point1.
The profit on realisation of securities by a bank to meet withdrawals was held to be taxable. It was not necessary to establish that the bank had been carrying on a separate business of buying and selling or realising investments for the profit on sale of the securities to be taxable2. (For the anti-avoidance provisions applying where changes in the fair value of securities (held for the purpose of carrying on a banking or insurance business or a business consisting of dealing in securities) are accounted for in reserves (either in the statement of recognised gains and losses or statement of changes in
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