Commentary

D1.749 Change of ownership—non-trading loan relationship deficits and debits

Corporate tax
Corporate tax | Commentary

D1.749 Change of ownership—non-trading loan relationship deficits and debits

Corporate tax | Commentary

D1.749 Change of ownership—non-trading loan relationship deficits and debits

Restriction on non-trading deficits on loan relationships

Where a company has a change in ownership on or after 1 April 2017 and, within a certain timeframe, there is a major change in the business of the company which has been transferred to new ownership, or a co-transferred company, then there are restrictions on the utilisation of non-trading deficits carried forward which are post 1 April 2017 and which arose prior to the change in ownership. The restriction is on the utilisation against 'affected' profits which are broadly profits that arise in the five years after the change in ownership. The restrictions are detailed further in 'Extension of restriction for post 1 April 2017 losses (Chapter 2A)' in

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