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Legislation
Corporation Tax Act 2010

Chapter 2 Disallowance of trading losses

  • Section 673 Introduction to Chapter
  • Section 674 Disallowance of trading losses
  • Section 674A Section 674: exception for certain losses of ring fence trade
  • Section 675 Disallowance of trading losses: calculation of balancing charges
  • Section 676 Company reconstructions
  1. Chapter 2 · Disallowance of trading losses
  2. Introduction to Chapter

Section 673 | Introduction to Chapter

From legislation.gov.uk

(1)This Chapter applies if—

(a)there is a change in the ownership of a company (“the company”), and

(b)condition A or B is met.

(2)Condition A is that within any period beginning no more than 3 years before the change in ownership occurs which is a period of 5 years in which that change occurs there is a major change in the nature or conduct of a trade carried on by the company.

(3)Condition B is that the change in ownership occurs at any time after the scale of the activities in a trade carried on by the company has become small or negligible and before any significant revival of the trade.

(4)In this section “major change in the nature or conduct of a trade” includes—

(a)a major change in the type of property dealt in, or services or facilities provided in, the trade, or

(b)a major change in customers, outlets or markets of the trade.

This Chapter applies even if the change is the result of a gradual process which began before the period of 5 years mentioned in subsection (2).

(5)In this Chapter—

“the change in ownership” means the change in ownership mentioned in subsection (1),

“the company” has the same meaning as in this section, and

“trade” includes an office.

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