Commentary

D2.403 Loss restriction

Corporate tax
Corporate tax | Commentary

D2.403 Loss restriction

Corporate tax | Commentary

D2.403 Loss restriction

Where the conditions detailed at D2.402, are met there is a restriction on the ability to offset capital losses against capital gains, as follows:

  1.  

    •     For disposals of pre-change assets (D2.404–D2.406) occurring on or after 21 March 2007, the qualifying loss cannot be deducted from chargeable gains accruing to the company1. This ensures that a company with qualifying losses cannot use them to reduce gains on the disposal of shares in a directly held subsidiary where the gains are attributable to an increase in the value of assets the subsidiary holds, but which were acquired after the change of ownership

  2.  

    •     For disposals of pre-change

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