Skip to content
Solved

CTM07530 | Corporation Tax: tax avoidance involving carried-forward losses: deductible amounts

From HM Revenue & Customs · Company Taxation Manual

The ‘deductible amount’ meeting condition B (CTM07520) 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) (CA60000 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 CTA09/S1219;

  • A non-trading debit on a loan relationship or derivative contract under CTA09/PART5 or PART 6 (see CTA09/S301 (2)); or

  • A non-trading debit on intangible fixed assets under CTA09/PART8 (see CTA09/S746).

Deductible amount does not include an amount taken into account in determining the relevant tax written-down value (RTWDV) for the purpose of CAA01/S212K 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 (CTA10/S730H (2)).