Commentary

D1.1131 Anti-avoidance—other corporate tax loss measures

Corporate tax
Corporate tax | Commentary

D1.1131 Anti-avoidance—other corporate tax loss measures

Corporate tax | Commentary

D1.1131 Anti-avoidance—other corporate tax loss measures

Anti-avoidance—shell company losses

A shell company is defined as a company that is not trading, does not have investment business and is not carrying on a UK property business1. For a change in ownership (see D1.1125) of a shell company there are restrictions on the availability of non-trading debits, non-trading loan relationship deficits and non-trading losses on intangible fixed assets2.

On the change of ownership, the accounting period in which the change of ownership occurs (AP) is split into two notional accounting periods3. The first notional accounting period (AP1) ending with the date of change and the second (AP2) covering the balance of the period.

The profits or losses of

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