UK corporation tax for companies resident in the UK and for non-resident companies trading in the UK through a permanent establishment. Covers the 25% main rate, the 19% small profits rate and marginal relief between GBP 50,000 and GBP 250,000 (limits shared by associated companies and cut for sh…
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Accountant-authored. Written and published by Ryan Duguid, an accountant approved on OpenAccountants. Their licence number is not on file. Their registration is in Australia; this skill covers United Kingdom. General reference material, not advice on your specific facts; don't file, pay, or take a position on it without a professional reviewing your situation.
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| Item | Rate or amount | Tax year | Source |
|---|---|---|---|
| Main rate (profits over the upper limit) | 25% | FY2026 (1 Apr 2026 to 31 Mar 2027); same for FY2023 to FY2025 | Finance Act 2025 s13; HMRC rates and allowances |
| Small profits rate (profits at or below the lower limit) | 19% | FY2026 | Finance Act 2025 s14 |
| Lower limit | £50,000 | FY2026 | CTA 2010 s18D |
| Upper limit | £250,000 | FY2026 | CTA 2010 s18D |
| Standard marginal relief fraction | 3/200 | FY2026 | Finance Act 2025 s14 |
| Main rate, small profits rate and fraction, next year | 25%, 19% and 3/200 (limits unchanged at £50,000 and £250,000) | FY2027 (1 Apr 2027 to 31 Mar 2028) | Finance Act 2026 s11; Finance Act 2026 s12; CTA 2010 s18D |
| Marginal relief formula | F x (U - A) x N / A | all years from FY2023 | CTA 2010 s18B; HMRC CTM03925 |
| Associated companies | both limits divided by (1 + number of associated companies) | FY2026 | HMRC marginal relief guidance |
| Short accounting period | both limits reduced in proportion | FY2026 | CTA 2010 s18D |
| Unit trusts and OEICs | 20% | FY2026 | HMRC rates and allowances |
| Ring fence profits (oil and gas) | 30% main, 19% small, fraction 11/400 | FY2026 | HMRC rates and allowances |
| Loss deductions allowance (company not in a group) | £5,000,000 a year, cut for short periods | FY2026 | CTA 2010 s269ZW |
| Loss deductions allowance (group) | one £5,000,000 shared across the group | FY2026 | CTA 2010 s269ZR |
| Profits above the deductions allowance that brought-forward losses can cover | 50% | FY2026 | CTA 2010 s269ZB; s269ZD |
| Corporate interest restriction de minimis | £2,000,000 net interest a year for the worldwide group | FY2026 | TIOPA 2010 s392 |
| Corporate interest restriction fixed ratio | 30% of tax-EBITDA (lower of that and the fixed ratio debt cap) | FY2026 | TIOPA 2010 s397 |
| Annual Investment Allowance | £1,000,000 | since 1 Jan 2019 | gov.uk AIA |
| Full expensing (new main rate plant, companies only) | 100% first-year allowance | expenditure from 1 Apr 2023 | CAA 2001 s45S; HMRC CA23174AA |
| Special rate plant first-year allowance (companies) | 50% | expenditure from 1 Apr 2023 | HMRC CA23174AA |
| New first-year allowance (new main rate plant, includes some leased plant) | 40% | expenditure from 1 Jan 2026 | Finance Act 2026 s29 (new CAA 2001 s45U) |
| Main pool writing-down allowance | 14% (was 18%); hybrid rate for a period spanning 1 Apr 2026 | periods from 1 Apr 2026 | Finance Act 2026 s28 |
| Large company (quarterly instalments) | profits over £1.5m, shared by associated companies | FY2026 | HMRC instalments guidance |
| Very large company (earlier instalments) | profits over £20m; for periods beginning on or after 1 Apr 2023 divided by (1 + number of associated companies) | periods from 1 Apr 2019 | SI 2017/1072; HMRC very large company guidance |
| Pillar Two | Multinational top-up tax and domestic top-up tax at a 15% minimum rate for groups with revenue over EUR 750m in two of the four prior periods; in force for periods beginning on or after 31 Dec 2023 (UTPR from 31 Dec 2024) | in force | HMRC MTT01100; HMRC MTT01010 |
Corporation tax is charged by financial year. A financial year runs from 1 April to 31 March and is named after the calendar year in which it starts, so financial year 2026 runs from 1 April 2026 to 31 March 2027. A company's accounting period that straddles 31 March is split between the two financial years on a time basis when the rates differ. For financial years 2023 to 2027 the rates, limits and fraction are the same, so current periods need no split.
The law is mainly the Corporation Tax Act 2009 (CTA 2009), the Corporation Tax Act 2010 (CTA 2010), the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), the Taxation of Chargeable Gains Act 1992 (TCGA 1992), Schedule 18 to the Finance Act 1998 (returns and penalties) and the yearly Finance Acts. HMRC's own guidance is on gov.uk and in the HMRC internal manuals.
| Item | Rate or amount | Tax year | Source |
|---|---|---|---|
| Main rate (profits over the upper limit) | 25% | FY2026 (1 Apr 2026 to 31 Mar 2027); same for FY2023 to FY2025 | Finance Act 2025 s13; HMRC rates and allowances |
| Small profits rate (profits at or below the lower limit) | 19% | FY2026 | Finance Act 2025 s14 |
| Lower limit | £50,000 | FY2026 | CTA 2010 s18D |
| Upper limit | £250,000 | FY2026 | CTA 2010 s18D |
| Standard marginal relief fraction | 3/200 | FY2026 | Finance Act 2025 s14 |
| Main rate, small profits rate and fraction, next year | 25%, 19% and 3/200 (limits unchanged at £50,000 and £250,000) | FY2027 (1 Apr 2027 to 31 Mar 2028) | Finance Act 2026 s11; Finance Act 2026 s12; CTA 2010 s18D |
| Marginal relief formula | F x (U - A) x N / A | all years from FY2023 | CTA 2010 s18B; HMRC CTM03925 |
| Associated companies | both limits divided by (1 + number of associated companies) | FY2026 | HMRC marginal relief guidance |
| Short accounting period | both limits reduced in proportion | FY2026 | CTA 2010 s18D |
| Unit trusts and OEICs | 20% | FY2026 | HMRC rates and allowances |
| Ring fence profits (oil and gas) | 30% main, 19% small, fraction 11/400 | FY2026 | HMRC rates and allowances |
| Loss deductions allowance (company not in a group) | £5,000,000 a year, cut for short periods | FY2026 | CTA 2010 s269ZW |
| Loss deductions allowance (group) | one £5,000,000 shared across the group | FY2026 | CTA 2010 s269ZR |
| Profits above the deductions allowance that brought-forward losses can cover | 50% | FY2026 | CTA 2010 s269ZB; s269ZD |
| Corporate interest restriction de minimis | £2,000,000 net interest a year for the worldwide group | FY2026 | TIOPA 2010 s392 |
| Corporate interest restriction fixed ratio | 30% of tax-EBITDA (lower of that and the fixed ratio debt cap) | FY2026 | TIOPA 2010 s397 |
| Annual Investment Allowance | £1,000,000 | since 1 Jan 2019 | gov.uk AIA |
| Full expensing (new main rate plant, companies only) | 100% first-year allowance | expenditure from 1 Apr 2023 | CAA 2001 s45S; HMRC CA23174AA |
| Special rate plant first-year allowance (companies) | 50% | expenditure from 1 Apr 2023 | HMRC CA23174AA |
| New first-year allowance (new main rate plant, includes some leased plant) | 40% | expenditure from 1 Jan 2026 | Finance Act 2026 s29 (new CAA 2001 s45U) |
| Main pool writing-down allowance | 14% (was 18%); hybrid rate for a period spanning 1 Apr 2026 | periods from 1 Apr 2026 | Finance Act 2026 s28 |
| Large company (quarterly instalments) | profits over £1.5m, shared by associated companies | FY2026 | HMRC instalments guidance |
| Very large company (earlier instalments) | profits over £20m; for periods beginning on or after 1 Apr 2023 divided by (1 + number of associated companies) | periods from 1 Apr 2019 | SI 2017/1072; HMRC very large company guidance |
| Pillar Two | Multinational top-up tax and domestic top-up tax at a 15% minimum rate for groups with revenue over EUR 750m in two of the four prior periods; in force for periods beginning on or after 31 Dec 2023 (UTPR from 31 Dec 2024) | in force | HMRC MTT01100; HMRC MTT01010 |
There is no local or regional tax on company profits in the UK and no minimum tax for ordinary companies outside Pillar Two.
How marginal relief works. Work out tax on taxable total profits (N) at the 25% main rate. Then deduct marginal relief: 3/200 x (upper limit - augmented profits) x (taxable total profits / augmented profits). Augmented profits (A) are taxable total profits plus exempt distributions received, other than distributions from a 51% subsidiary or a company of which the recipient is a 51% subsidiary (CTA 2010 s18L). Between the limits the effective marginal rate on each extra pound is 26.5%. If augmented profits are at or below the lower limit, the whole of taxable total profits is taxed at 19%.
Associated companies. Two companies are associated if one controls the other or both are under the control of the same person or persons. Rights held by a participator's associates (such as relatives) are counted only where there is substantial commercial interdependence between the companies; rights the participators hold themselves always count (HMRC CTM03950). HMRC's example: a company with 3 other associated companies divides the limits by 4, giving a lower limit of £12,500 and an upper limit of £62,500 (HMRC marginal relief guidance).
Next year. Finance Act 2026 charges corporation tax for financial year 2027 (1 April 2027 to 31 March 2028) at a 25% main rate (s11), with a 19% standard small profits rate and a 3/200 standard marginal relief fraction (s12). The £50,000 and £250,000 limits are fixed in CTA 2010 s18D and did not change, so an accounting period straddling 31 March 2027 needs no split.
Start with the profit before tax in the accounts (UK GAAP or IFRS) and adjust it into taxable total profits.
| Step | Deadline | Source |
|---|---|---|
| Tell HMRC the company is within corporation tax | within 3 months after the start of its first accounting period | Finance Act 2004 s55 |
| Pay corporation tax (not large) | 9 months and 1 day after the end of the accounting period | gov.uk Pay Corporation Tax |
| Large company (profits over £1.5m, under £20m) | four equal instalments: 6 months 13 days after the start of the period, then every 3 months, the last 3 months 14 days after the period ends (months 7, 10, 13 and 16 of a 12-month period) | HMRC instalments guidance |
| Very large company (profits over £20m, divided among associated companies) | four instalments on the 14th day of months 3, 6, 9 and 12 of the period | HMRC CTM92805; HMRC very large company guidance |
| File the Company Tax Return (CT600) | 12 months after the end of the accounting period | gov.uk Company Tax Returns |
| Failure | Penalty or rate | Source |
|---|---|---|
| Return late, filing date on or after 1 April 2026 | £200 flat; £400 if more than 3 months late | FA 1998 Sch 18 para 17(2); Finance Act 2026 s265 |
| Third return in a row late, filing date on or after 1 April 2026 | £1,000 flat; £2,000 if more than 3 months late | FA 1998 Sch 18 para 17(3); Finance Act 2026 s265 |
| Return late, filing date before 1 April 2026 | £100 flat; £200 if more than 3 months late; third in a row £500 and £1,000 | Finance Act 2026 s265 (the amounts it replaced) |
| Return not filed within 18 months of the period end | extra 10% of unpaid tax; 20% if filed more than 2 years after the period end | FA 1998 Sch 18 para 18 |
| Inaccurate return | up to 30% (careless), 70% (deliberate) or 100% (deliberate and concealed) of the potential lost revenue for a domestic (category 1) inaccuracy, reduced for disclosure; higher maximums for offshore categories 2 and 3 | FA 2007 Sch 24 para 4 |
| Late payment interest | Bank of England base rate plus 4% (from 6 April 2025); 7.75% from 9 January 2026 | HMRC interest rates |
| Underpaid quarterly instalments | 6.25% from 29 December 2025 | HMRC interest rates |
| Repayment interest | base rate minus 1%, minimum 0.5%; 2.75% from 9 January 2026 | HMRC interest rates |
The doubled flat penalties apply to returns whose filing date is 1 April 2026 or later, which for a company on the normal 12-month filing date means accounting periods ending on or after 1 April 2025; earlier returns keep £100, £200, £500 and £1,000 (Finance Act 2026 s265(2)). HMRC may now change these amounts by regulations (new para 17(5)). The HMRC interest page was last updated on 23 December 2025, and the Bank of England's Bank Rate has stayed at 3.75% since 18 December 2025 (Bank of England Bank Rate history), so the rates above were current when read; they move with Bank Rate, so check on the day you compute. There is no separate fixed late payment penalty for corporation tax; interest runs from the due date. HMRC estimates the tax (a determination) if the return is 6 months late (gov.uk late filing penalties).
Brightwell Joinery Ltd has no associated companies and no dividend income. Its accounts run for the year 1 April 2026 to 31 March 2027, which falls wholly in financial year 2026. Profit before tax is £180,000. The accounts charge £22,000 of depreciation and £3,000 of client entertaining. In the year it bought a new CNC machine for £30,000, which qualifies for full expensing.
Taxable trading profit is 180,000 + 22,000 + 3,000 - 30,000 = £175,000. That is between the £50,000 and £250,000 limits, so marginal relief applies. Tax at the main rate is 175,000 x 25% = £43,750. Marginal relief is 3/200 x (250,000 - 175,000) x 175,000 / 175,000 = £1,125. Corporation tax payable is £42,625. It is not a large company, so the tax is due on 1 January 2028 (9 months and 1 day after 31 March 2027) and the CT600 is due by 31 March 2028.
name: Single company, taxable profit GBP 175,000, FY2026, no associated companies
inputs:
accounts_profit: 180000
depreciation: 22000
entertaining: 3000
full_expensing: 30000
main_rate: 25
lower_limit: 50000
upper_limit: 250000
steps:
- fraction: 3 / 200
- ttp: accounts_profit + depreciation + entertaining - full_expensing
- augmented: ttp
- tax_main: pct(ttp, main_rate)
- marginal_relief: fraction * (upper_limit - augmented) * ttp / augmented
- ct: tax_main - marginal_relief
expected:
ttp: 175000
tax_main: 43750
marginal_relief: 1125
ct: 42625
Harrow Lane Trading Ltd is controlled by the same individual who controls one other trading company, so it has one associated company. The limits are divided by 2: lower limit £25,000, upper limit £125,000. Its year runs 1 April 2026 to 31 March 2027. Adjusted trading profit is £140,000. It has £60,000 of trade losses brought forward from the year to 31 March 2026. It also received a £10,000 dividend on a 4% holding in an unrelated UK company, which is exempt as a portfolio holding but counts in augmented profits.
The loss is well under the £5m deductions allowance, so all of it can be used: taxable total profits are 140,000 - 60,000 = £80,000. Augmented profits are 80,000 + 10,000 = £90,000, which is between the reduced limits. Tax at the main rate is 80,000 x 25% = £20,000. Marginal relief is 3/200 x (125,000 - 90,000) x 80,000 / 90,000 = £466.67. Corporation tax payable is £19,533.33. Without the associated company, augmented profits of £90,000 would sit further below the £250,000 upper limit and the relief would be larger; the association costs this company tax.
name: Losses brought forward, one associated company, exempt portfolio dividend, FY2026
inputs:
trading_profit: 140000
losses_bf: 60000
exempt_dividend: 10000
associated: 1
deductions_allowance: 5000000
main_rate: 25
steps:
- fraction: 3 / 200
- lower_limit: 50000 / (1 + associated)
- upper_limit: 250000 / (1 + associated)
- loss_cap: min(trading_profit, deductions_allowance) + pct(max(trading_profit - deductions_allowance, 0), 50)
- loss_used: min(losses_bf, loss_cap)
- ttp: trading_profit - loss_used
- augmented: ttp + exempt_dividend
- tax_main: pct(ttp, main_rate)
- marginal_relief: round(fraction * (upper_limit - augmented) * ttp / augmented, 2)
- ct: tax_main - marginal_relief
expected:
lower_limit: 25000
upper_limit: 125000
loss_used: 60000
ttp: 80000
augmented: 90000
tax_main: 20000
marginal_relief: 466.67
ct: 19533.33
Not yet confirmed: whether a tax treaty's non-discrimination article lets a UK permanent establishment of a non-resident company use the small profits rate or marginal relief despite CTA 2010 ss18A and 18B.
Contributed by Ryan Duguid.
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