LAM15080 | Excess expenses, losses and deficits:  Set-off of non-BLAGAB capital losses: TCGA92/S2A and TCGA92/210A

Capital losses not arising from BLAGAB may be either set off against any capital gains not arising from BLAGAB (TCGA92/S2A(1)(a)). Any excess losses can be:

• carried forward to the next period and set against chargeable gains not arising from BLAGAB in the subsequent periods (TCGA92/S2A(1)(b));

• if there are any remaining carried forward losses, they can be set against the shareholders’ share of any BLAGAB gains in the subsequent period (TCGA92/S210A). TCGA/S210A was amended as part of the capital loss restriction legislation which came into force on 1 April 2020. The guidance can be found in CG-APP17. Section 10 of that guidance covers life insurance companies and Section 5A covers the Straddling Period.