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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Meaning of certain expressions that first appear in section 147

  • Section 149 “Actual provision” and “affected persons”
  • Section 150 “Transaction” and “series of transactions”
  • Section 151 “Arm's length provision”
  • Section 152 Arm's length provision where actual provision relates to securities
  • Section 153 Arm's length provision where security issued and guarantee given
  • Section 153A Certain guarantees not capable of being arm’s length
  • Section 153B Election for deemed guarantee
  • Section 154 Interpretation of sections 153A and 153B
  • Section 155 “Potential advantage” in relation to United Kingdom taxation
  • Section 156 “Losses” and “profits”
  1. Meaning of certain expressions that first appear in section 147
  2. “Losses” and “profits”

Section 156 | “Losses” and “profits”

From legislation.gov.uk

(1)In this Part “losses” includes amounts which are not losses but in respect of which relief may be given in accordance with the Tax Acts including (for example)—

(a)section 57 of ITTOIA 2005 (pre-trading expenses),

(b)section 88 of ITA 2007 (carry forward of certain interest),

(c)section 61 of CTA 2009 (pre-trading expenses),

(d)sections 387 to 391 of CTA 2009 (insurance companies: non-trading deficits on loan relationships),

(e)Chapter 16 or Chapter 16A of Part 5 of CTA 2009 (non-trading deficits on loan relationships),

(f)section 1223 of CTA 2009 (excess of management expenses), ...

(g)Part 5 of CTA 2010 (group relief) , or

(2)In this Part “profits” includes income.

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