Section 676AH | Restriction on the carry forward of post-1 April 2017 non-trading deficit from loan relationships

(1)This section has effect for the purpose of restricting the carry forward under Chapter 16A of Part 5 of CTA 2009 (non-trading deficits: post 1 April 2017 deficits) of a pre-acquisition non-trading deficit from the transferred company's loan relationships.

(2)For the purposes of this section an amount is a “pre-acquisition” non-trading deficit from a company's loan relationships if it is a non-trading deficit from the company's loan relationships for an accounting period beginning before the change in ownership.

(3)Subsection (4) applies if, in the case of a pre-acquisition non-trading deficit from the transferred company's loan relationships, the non-trading deficit in column 1 of row 4 of the table in section 685(2) is apportioned in accordance with section 685(2) to the first notional accounting period.

(4)None of that deficit may, by virtue of section 463G (carry forward of unrelieved deficit), be set off against affected profits of—

(a)the accounting period beginning immediately after the change in ownership, or

(b)any subsequent accounting period.