CTM04710 | Corporation Tax: trading losses - relief against total profits: restrictions for farming companies

From HM Revenue & Customs · Company Taxation Manual

restricts loss relief of companies carrying on farming and market gardening trades in the UK or abroad. It excludes any loss incurred in carrying on such a trade from () if a loss was incurred in carrying on that trade:

  • in the accounting period,

  • and in each of the chargeable periods which falls wholly or partly in the five years prior to the accounting period.

For this purpose the loss is without regard to capital allowances and balancing charges. (This applies in spite of, for example, and , which provide that normally capital allowances are treated as trading expenses.) ‘Chargeable period’ means any accounting period, or any basis period ending before the company's first accounting period. The meaning of ‘basis period’ is found at .

There are certain exceptions to this restriction of loss relief. See CTM04720 and .

Other guidance

Where a company claims exemption from the general rule by applying , the guidance at to applies, substituting ‘accounting period’ for ‘year of assessment’.