Commentary

D2.401 Restrictions on relief―Summary

Corporate tax
Corporate tax | Commentary

D2.401 Restrictions on relief―Summary

Corporate tax | Commentary

Division D2.4     Pre-entry capital losses

For updates affecting this Division please see Part D0 Updates

Pre-entry capital losses—generally

D2.401 Restrictions on relief―Summary

The flexibility available to group companies when transferring assets could be open to abuse. Consequently specific provisions apply in order to prevent groups of companies avoiding tax by buying a company with capital losses. These provisions restrict the offset of capital losses against capital gains. Currently there are two sets of provisions:

  1.  

    (a)     the loss provisions which take precedence (D2.402–D2.407)1, and

  2.  

    (b)     rules denying relief where a company with unrelieved capital losses is moved into a group2. These rules

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