CTM04100 | Corporation Tax: trading losses: general: relief for losses carried forward: summary

From HM Revenue & Customs · Company Taxation Manual

, to 45H,

The treatment of carried forward losses was reformed by F(2)A17 which introduced changes to the tax treatment of carried forward losses providing increased flexibility in how losses arising from 1 April 2017 can be relieved.

Losses incurred before 1 April 2017

Losses incurred before 1 April 2017 can only be carried forward and set against profits of the same trade.

Carried forward pre 1 April 2017 trading losses are also unavailable for group relief, they are only available for group relief in the period in which they arise.

Losses incurred from 1 April 2017

The treatment of carried-forward trade losses incurred on or after 1 April 2017 depends on:

  • the period in which they were sustained, and

  • certain characteristics of the trade.

Companies can set off most .

Companies may also be able to claim or surrender losses incurred from 1 April 2017 as .

Trade losses incurred before 1 April 2017 and certain trade losses incurred at a later date are available for .