CTM06820 | Corporation Tax: loss buying: restriction of group relief for carried-forward losses: restriction of reliefs

CTA10/S676CH

CTA10/PART14/CH2C restricts reliefs for losses and other amounts incurred before the {change in ownership} and carried forward under the following provisions:

· Non-trading deficits from loan relationships carried forward against total profits (CTA09/S463G(6)),

· Non-trading losses on intangible fixed assets carried forward (CTA09/S753(3)),

· Expenses of management carried forward (CTA09/S1223),

· Post-April 2017 trade losses carried forward against total profits (CTA10/S45A(3)),

· UK property business losses carried forward (CTA10/S62(5)(b), S63(3)(a)),

· Excess carried-forward non-decommissioning losses of oil and gas ring fence trades (CTA10/S303B(2), S303D(3)),

· Excess carried-forward BLAGAB trade losses (FA12/S124A(2),S124C(3)).