The following Corporation Tax guidance note by Tolley in partnership with Jackie Barker of Wells Associates provides comprehensive and up to date tax information covering:
This note provides details of the potential restriction that may arise in respect of losses on a change in ownership of a company with investment business. The restrictions are very similar to those which apply in respect of trading losses. See the Trading losses and anti-avoidance guidance note for more information.
The legislation in CTA 2010, ss 677–691 sets out various conditions in relation to the change in ownership of an investment company which, if met, will result in potential restrictions to the excess management expenses, qualifying donations and non-trading loan relationship deficits that have arisen. The purpose of this is to ensure that companies are not ‘traded’ just so a tax advantage can be obtained.
For details regarding excess management changes in general, please refer to the Excess management expenses guidance note.
The conditions which lead to the potential restrictions are that there is a change in ownership of a company with an investment business and one of the following applies:
CTA 2010, s 677
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