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CTM08780 | Corporation Tax: change of ownership: companies with investment business: excess over profits

From HM Revenue & Customs · Company Taxation Manual

CTA10/S679 onwards

Where CTA10/S677 applies

  • any profits of the company that relate to an accounting period (or notional AP) ending after the change in ownership cannot be reduced by any excess of management expenses, charges and interest that accrued before the change in ownership,

and

  • the extent to which loan relationship debits (and non-trading loan relationship deficits for changes in ownership on or after 10 February 2005) can be brought into account in computing the profits of APs that follow the change in ownership is restricted.