Commentary

D2.254 Group relief and loss buying (the deduction transfer TAAR)

Corporate tax
Corporate tax | Commentary

D2.254 Group relief and loss buying (the deduction transfer TAAR)

Corporate tax | Commentary

D2.254 Group relief and loss buying (the deduction transfer TAAR)

Finance Act 2013 introduced a wide ranging restriction on the deductibility of certain expenses which, broadly, prevents the deduction of certain expenses in a group relief or loss relief claim after a qualifying change in relation to a company if the main purpose of the change was for the expense to be brought into account in the claim1. This is commonly referred to as the 'deduction transfer TAAR'.

It applies to qualifying changes on or after 20 March 2013 unless either arrangements to bring about the qualifying change had been

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