CTM06775 | Corporation Tax: loss buying: major change in the business of a transferred company: priority of provisions

From HM Revenue & Customs · Company Taxation Manual

The provisions of do not apply where or CHAPTER3 can be used instead.

This is achieved through priority rules, which operate where a loss or other amount meets the conditions of but could also be restricted under any of the following provisions

  • disallowance of trading losses (), and

  • restrictions on relief for companies with investment business (CTA10/PART14/CHAPTER3/S679 to S683).

In these circumstances, the provision in CHAPTER2A that would otherwise restrict the loss does not apply. The available provision of CHAPTER2 or CHAPTER3 is used instead.