CTM07515 | Corporation Tax: tax avoidance involving carried-forward losses: relevant carried-forward losses
From HM Revenue & Customs · Company Taxation Manual
The rules apply to tax arrangements involving several types of carried-forward relief, referred to together in the legislation as ‘relevant carried-forward losses’:
Trading losses carried-forward under , S45A or S45B;
Non-trading loan relationship deficits carried-forward under , S463G or S463H; and
Management expenses carried-forward under .
Management expenses includes carried-forward qualifying charitable donations made for the purposes of an investment business and unused losses of a ceased UK property business ().
For accounting periods (APs) beginning on or after 1 April 2017, the following types of losses are also included as ‘relevant carried-forward losses’:
UK property business losses carried-forward under ; and
Non-trading losses on intangible fixed assets carried-forward under .
Where an AP straddles 1 April 2017, it is spilt into two notional accounting periods with amounts apportioned on a time basis or on a just and reasonable basis if the time basis produces a result which is unjust and unreasonable.