CTM06715 | Corporation Tax: loss buying: provisions introduced in F(2)A 2017

CTA10/PART14/CHAPTER2A to CHAPTER2E

CTA10/CHAPTER2A to CHAPTER 2E extend pre-existing rules found in CTA10/PART14 and CTA10/PART14A to counter loss buying in a number of circumstances.

These provisions only apply where there has been a change in company ownership on or after 1 April 2017. Their effect is to restrict the ways in which that company can use losses and other amounts incurred before the change.

CTA10/CHAPTER2A extends the restrictions on relief where there is a major change in the business of a company (CTM06740) in addition to the change in ownership.

CTA10/CHAPTER2B and CHAPTER2D (CTM06780) extend restrictions on relief in situations where an asset has been transferred to the company following a change in ownership.

CTA10/CHAPTER2C restricts group relief for carried-forward losses (CTM06810) following a change in ownership.

CTA10/CHAPTER2E (CTM06850) restricts relief for trading losses in situations where there has been a change in ownership and a transfer of trade.