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Contents

Official guidance
Company Taxation Manual

CTM04800 · Corporation tax: CT loss reform

  • CTM04810 · Introduction
  • CTM04820 · Scope
  • CTM04830 · Restriction
  • CTM04835 · Corporation Tax: CT loss restriction: administrative requirements for the deductions allowance
  • CTM04836 · Administrative requirements: template for the group allowance allocation statement
  • CTM04840 · Relaxation
  • CTM04850 · Group relief for carried-forward losses
  • CTM04860 · Claims
  • CTM04870 · Anti-avoidance
  • CTM04880 · Commencement and apportionment
  • CTM04890 · Commencement: companies affected by the corporate interest restriction
  • CTM04900 · Commencement: note concerning examples
  • CTM04910 · Commencement: example 1: company makes overall loss in the AP straddling 1 April 2017
  • CTM04920 · Commencement: example 2: alternative treatment of NTLRDs arising in the AP straddling 1 April 2017
  • CTM04930 · Commencement: example 3: company makes overall profit in the AP straddling 1 April 2017: no carried-forward losses relieved in the period
  • CTM04940 · Commencement: example 4: company makes overall profit in the AP straddling 1 April 2017: carried-forward losses relieved in the period
  • CTM04950 · Commencement: example 5: company makes overall profit in the AP straddling 1 April 2017: carried-forward losses relieved in the period and losses carried-forward from the period
  • CTM04960 · Commencement: example 6: company makes overall profit in the AP straddling 1 April 2017: carried-forward losses relieved in the period and group relief
  • CTM04970 · Commencement: example 7: company makes overall profit due to the effects of the corporate interest restriction
  1. Corporation tax: CT loss reform: contents
  2. Corporation tax: CT loss reform: commencement: note concerning examples

CTM04900 | Corporation tax: CT loss reform: commencement: note concerning examples

From HM Revenue & Customs · Company Taxation Manual

The following examples, at CTM04910 to CTM04970, show when apportionment is necessary, and what types of amounts should be apportioned.

For the purposes of simplicity, unless otherwise stated, in all of the examples below:

  • Apportionment on a time basis has been made by reference to months. In practice, this should normally be made by reference to days.

  • It is assumed that apportioning on a time basis gives a just and reasonable result.

  • The deductions allowance available to groups when calculating the loss restriction has been treated as being nil.

  • It is assumed that all necessary claims have been made to set off losses and other amounts to the full extent possible. This applies for both amounts incurred in and carried forward to the straddling period.

  • NTLR deficits are apportioned only to the extent necessary, as set out above.

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