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Contents

Official guidance
Business Income Manual

BIM85700 · restriction of relief

  • BIM85701 · Trade losses - restriction of relief: introduction
  • BIM85703 · Trade losses - restriction of relief: interaction with the income tax reliefs cap
  • BIM85705 · Trade losses - restriction of relief: uncommercial trades - not on a commercial basis
  • BIM85710 · Trade losses - restriction of relief: uncommercial trades - not with a view to the realisation of profit
  • BIM85715 · Trade losses - restriction of relief: change in conduct of trade
  • BIM85720 · Trade losses - restriction of relief: larger undertaking
  • BIM85725 · Trade losses - restriction of relief: partners
  • BIM85730 · Trade losses - restriction of relief: inclusion of capital allowances
  • BIM85735 · Trade losses - restriction of relief: uncommercial losses made in early years of trade
  • BIM85740 · Trade losses - restriction of relief: contrived trading losses
  • BIM85750 · Trade losses - restriction of relief: first year allowances and annual investment allowances
  • BIM85760 · Trade losses - restriction of relief: income not eligible/losses not eligible
  • BIM85761 · No sideways relief for tax-generated losses
  • BIM85762 · Tax-generated losses
  • BIM85765 · Non-active traders - overview
  • BIM85766 · Non-active traders - annual limit
  • BIM85767 · Non-active traders - basis period straddling 12 March 2008
  • BIM85768 · Trade losses - restriction of relief: non-active traders - film-related expenditure
  • BIM85769 · Trade losses - restriction of relief: non-active traders - tax-generated losses 12 March 2008 to 20 October 2009
  • BIM85770 · Trade losses - restriction of relief: non-active traders - basis period straddles, or tax avoidance arrangements predate, 12 March 2008
  1. restriction of relief: contents
  2. restriction of relief: no sideways relief for tax-generated losses

BIM85761 | restriction of relief: no sideways relief for tax-generated losses

From HM Revenue & Customs · Business Income Manual

Overview

S74ZA Income Tax Act 2007 (ITA 2007)

S74ZA ITA 2007 is an anti-avoidance measure which denies sideways loss relief for tax-generated losses made by a person (sole trader, partner, trustee) in a trade, profession or vocation. It applies to losses from relevant tax avoidance arrangements entered into on or after 21 October 2009. See BIM85762.

This provision replaces the previous rule denying sideways loss relief for tax-generated losses made on or after 12 March 2008 in a trade, but not profession or vocation, carried on by an individual in a non-active capacity, see BIM85765. It also replaces the previous bar on sideways loss relief for tax-motivated losses in a trade of dealing in commodity futures.

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