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Legislation
Corporation Tax Act 2010

CHAPTER 2A Post-1 April 2017 losses: Further cases involving a change in the company's activities

  • Section 676AA Introduction to Chapter
  • Section 676AB Priority of provisions of Chapters 2 and 3 over this Chapter
  • Section 676AC “Major change in the business” of a company
  • Section 676AD Notional split of accounting period in which change in ownership occurs
  • Section 676AE “Affected profits”
  • Section 676AF Restriction on use of carried-forward post-1 April 2017 trade losses
  • Section 676AG Restriction on debits to be brought into account
  • Section 676AH Restriction on the carry forward of post-1 April 2017 non-trading deficit from loan relationships
  • Section 676AI Restriction on relief for post-1 April 2017 non-trading loss on intangible fixed assets
  • Section 676AJ Restriction on deduction of post-1 April 2017 expenses of management
  • Section 676AK Restriction on use of post-1 April 2017 UK property business losses
  • Section 676AL “Co-transferred company” and “related company”
  1. Chapter 2A
  2. Restriction on relief for post-1 April 2017 non-trading loss on intangible fixed assets

Section 676AI | Restriction on relief for post-1 April 2017 non-trading loss on intangible fixed assets

From legislation.gov.uk

(1)This section has effect for the purpose of restricting relief under section 753 of CTA 2009 (treatment of non-trading losses) in respect of a relevant non-trading loss on intangible fixed assets.

(2)An amount is a “relevant non-trading loss on intangible fixed assets” if and so far as—

(a)it is by virtue of section 751 of CTA 2009 a non-trading loss on intangible fixed assets for a relevant pre-acquisition accounting period, or

(b)it is made up of an amount falling within paragraph (a) which has been carried forward under section 753(3) of CTA 2009.

(3)“Relevant pre-acquisition accounting period” means an accounting period beginning—

(a)before the change in ownership, and

(b)on or after 1 April 2017.

(4)In the case of a relevant non-trading loss on intangible fixed assets, relief under section 753 of CTA 2009 against the total profits of the actual accounting period is available only in relation to each of the notional accounting periods considered separately.

(5)A relevant non-trading loss on intangible fixed assets may not be deducted as a result of section 753(3) of CTA 2009 (losses carried forward) from affected profits of an accounting period ending after the change in ownership.

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