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Contents

Official guidance
Investment Funds Manual

IFM23000 · Real Estate Investment Trust : Entry to the regime

  • IFM23005 · Overview
  • IFM23010 · Notice to join: CTA2010/S523 and S524
  • IFM23015 · Effects of entry: cessation of business and accounting period: CTA2010/S536
  • IFM23020 · Effects of entry: deemed sale and reacquisition of assets: CTA2010/S536
  • IFM23025 · Entry charge prior to 17th July 2012: outline
  • IFM23100 · Effects of entry: capital losses from pre-entry periods: CTA2010/S541
  • IFM23105 · Effects of entry: trading and other losses from pre-entry periods: CTA2010/S541
  • IFM23110 · Effects of entry: other expenses etc pre-entry periods: CTA2010/S541
  1. Real Estate Investment Trust : Entry to the regime: contents
  2. Real Estate Investment Trust : Entry to the regime: effects of entry: trading and other losses from pre-entry periods: CTA2010/S541

IFM23105 | Real Estate Investment Trust : Entry to the regime: effects of entry: trading and other losses from pre-entry periods: CTA2010/S541

From HM Revenue & Customs · Investment Funds Manual

The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below and for Table 1: capital losses

Table 2: trading and other losses etc

##### Description##### Type of loss etc##### Can be used against
Qualifying UK property businessProperty lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other UK property businessProperty rental loss (CTA2010/S62)Profits of the residual business
TradeTrading loss (CTA2010/S37)Trading profits of the same trade included in the residual business
Qualifying overseas property businessOverseas property lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other overseas property businessOverseas property loss (CTA2010/S66)Overseas profits of other overseas property business included in the residual business
Other overseas incomeOverseas trading loss (CTA2010/S37)Overseas profits from same source included in the residual business
Other chargeable incomeCTA2010/S91Other chargeable profits included in the residual business

The qualifying UK property business and overseas property business losses are lost on entry to the regime, on cessation of those businesses. There can be no later claims in respect of these losses.

See [The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below and for Table 1: capital losses

Table 2: trading and other losses etc

##### Description##### Type of loss etc##### Can be used against
Qualifying UK property businessProperty lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other UK property businessProperty rental loss (CTA2010/S62)Profits of the residual business
TradeTrading loss (CTA2010/S37)Trading profits of the same trade included in the residual business
Qualifying overseas property businessOverseas property lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other overseas property businessOverseas property loss (CTA2010/S66)Overseas profits of other overseas property business included in the residual business
Other overseas incomeOverseas trading loss (CTA2010/S37)Overseas profits from same source included in the residual business
Other chargeable incomeCTA2010/S91Other chargeable profits included in the residual business

The qualifying UK property business and overseas property business losses are lost on entry to the regime, on cessation of those businesses. There can be no later claims in respect of these losses.

See](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm23100) and [The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below and for Table 1: capital losses

Table 2: trading and other losses etc

##### Description##### Type of loss etc##### Can be used against
Qualifying UK property businessProperty lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other UK property businessProperty rental loss (CTA2010/S62)Profits of the residual business
TradeTrading loss (CTA2010/S37)Trading profits of the same trade included in the residual business
Qualifying overseas property businessOverseas property lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other overseas property businessOverseas property loss (CTA2010/S66)Overseas profits of other overseas property business included in the residual business
Other overseas incomeOverseas trading loss (CTA2010/S37)Overseas profits from same source included in the residual business
Other chargeable incomeCTA2010/S91Other chargeable profits included in the residual business

The qualifying UK property business and overseas property business losses are lost on entry to the regime, on cessation of those businesses. There can be no later claims in respect of these losses.

See [The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below and for Table 1: capital losses

Table 2: trading and other losses etc

##### Description##### Type of loss etc##### Can be used against
Qualifying UK property businessProperty lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other UK property businessProperty rental loss (CTA2010/S62)Profits of the residual business
TradeTrading loss (CTA2010/S37)Trading profits of the same trade included in the residual business
Qualifying overseas property businessOverseas property lossNo carry forward since business ceases at entry (CTA2010/S541(4))
Other overseas property businessOverseas property loss (CTA2010/S66)Overseas profits of other overseas property business included in the residual business
Other overseas incomeOverseas trading loss (CTA2010/S37)Overseas profits from same source included in the residual business
Other chargeable incomeCTA2010/S91Other chargeable profits included in the residual business

The qualifying UK property business and overseas property business losses are lost on entry to the regime, on cessation of those businesses. There can be no later claims in respect of these losses.

See](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm23100) and](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm23110) for Tables 1 and 3: capital losses and other expenses etc.

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