Commentary

D2.410 Overview

Corporate tax
Corporate tax | Commentary

D2.410 Overview

Corporate tax | Commentary

Other restrictions on pre-entry losses—General rules

D2.410 Overview

The rules in this article and D2.411–D2.455 apply only in cases where the loss buying rules (D2.402–D2.406) do not apply. This will normally be the case where there is no arrangement for avoiding tax, eg on a merger or takeover.

These provisions apply to accounting periods ending after 15 March 1993 and affect the set off of pre-entry losses (see D2.414) against chargeable gains that accrue after 15 March 19931. (They do not apply to losses of a company which joined the group before 1 April 1987; such loses are unrestricted).

In essence

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