Commentary

B8.210 Restrictions on sideways loss relief

Business tax
Business tax | Commentary

B8.210 Restrictions on sideways loss relief

Business tax | Commentary

B8.210 Restrictions on sideways loss relief

In certain circumstances 'sideways' loss relief is denied or restricted. Sideways loss relief is defined as loss relief against general income (B8.202) or loss relief in the early years of a trade (B8.206)1.

The restrictions operate to either essentially 'ring-fence' losses arising from certain activities or to prevent use of artificially contrived losses.

Losses arising from certain activities

Sideways loss relief is restricted for losses arising from the following activities:

  1.  

    •     leasing of plant and machinery, see B5.4172

  2.  

    •     oil extraction activities, see D7.9023

  3.  

    •     exploitation of films, see B5.5054

  4.  

    •     farming, market gardening and forestry, see B5.1755

Artificially contrived losses

Targeted

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