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Legislation
Corporation Tax Act 2010

CHAPTER 5 Relevant IP losses

  • Section 357E Company with relevant IP losses: set-off amount
  • Section 357EA Effect of set-off amount on company with more than one trade
  • Section 357EB Allocation of set-off amount within a group
  • Section 357EC Carry-forward of set-off amount
  • Section 357ED Company ceasing to carry on trade, etc
  • Section 357EE Transfer of a trade between group members
  • Section 357EF Payments between group members in consequence of section 357EB
  1. Chapter 5 · Relevant IP losses
  2. Carry-forward of set-off amount

Section 357EC | Carry-forward of set-off amount

From legislation.gov.uk

(1)This section applies where—

(a)there is a set-off amount in relation to a trade of a company for an accounting period, and

(b)the set-off amount has not been reduced to nil by the operation of section 357EA(2) or 357EB(2).

(2)The set-off amount (or so much of it as remains after the operation of section 357EA(2) or 357EB(2)) is to be reduced (but not to below nil) by the amount of any relevant IP profits of the trade of the company for the current accounting period.The “current accounting period” is the accounting period immediately following the accounting period mentioned in subsection (1)(a).

(3)Section 357A does not apply in relation to so much of the amount of relevant IP profits of the trade of the company for the current accounting period as is equal to the amount by which the set-off amount (or so much of it as remains after the operation of section 357EA(2) or 357EB(2)) is reduced under subsection (2).

(4)If any portion of the set-off amount remains after the operation of subsection (2), that portion (“the remaining portion”) is to be treated as the set-off amount in relation to the trade of the company for the current accounting period (and the provisions of this Chapter apply accordingly).

(5)If there are relevant IP losses of the trade of the company for the current accounting period, the set-off amount in relation to the trade of the company for that accounting period is the aggregate of the remaining portion and an amount equal to the amount of those relevant IP losses (and the provisions of this Chapter apply accordingly).

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