Corporate tax relief for losses—anti-avoidance
D1.1124A Summary of anti-avoidance on corporate tax loss relief
There are various anti-avoidance provisions restricting corporate tax losses, these are summarised below:
Anti-avoidance on corporate tax losses—change of ownership
Anti-avoidance provisions restrict the use of losses following a change of ownership. In summary where there is a change in ownership and also the following listed conditions the restrictions apply as summarised below:
|Major change in nature or conduct of trade of the company, or the company's activities become small or negligible.||Trading losses arising after the change in ownership cannot be relieved against profits arising before the change and losses carried forward cannot be relieved against trading profits or total profits.|
Relief is lost completely.
CTA 2010, Pt 14, Ch 2
|Post 1 April 2017 change in ownership and major change in the business of the company.||Losses eligible for carried forward relief against total profits are not available against post change of ownership profits, including terminal losses. |
Relief is lost for five years.
CTA 2010, Pt 14, Ch 2A
|Post 1 April 2017 change in ownership, and ||Trading losses available for carried forward relief, including terminal losses, are not available against the gain|
Relief is lost for gains within five years.
CTA 2010, Pt 14, Ch
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial