CTM07530 | Corporation Tax: tax avoidance involving carried-forward losses: deductible amounts
From HM Revenue & Customs · Company Taxation Manual
The ‘deductible amount’ meeting condition B () includes five possible forms of deduction:
An expense of a trade, but does not include research and development allowances treated as expenses of the trade by CAA01/S450 (a) ( onwards);
An expense of a UK property business or an overseas property business;
An expense of management of a company’s investment business within the meaning of ;
A non-trading debit on a loan relationship or derivative contract under or PART 6 (see ); or
A non-trading debit on intangible fixed assets under (see ).
Deductible amount does not include an amount taken into account in determining the relevant tax written-down value (RTWDV) for the purpose of allowance buying rules.
The deduction may be in the form of a relief from profits, a reduction in profits, the increase in a loss, or any other deduction that can reduce the taxable profits of the company or the connected company ().