Commentary

D2.414 Pre-entry loss—Definition

Corporate tax
Corporate tax | Commentary

D2.414 Pre-entry loss—Definition

Corporate tax | Commentary

D2.414 Pre-entry loss—Definition

The rules in this article apply only where the loss buying rules (D2.402–D2.406) do not apply. As a result, for accounting periods ending after 4 December 2005, the following provisions will normally only apply in cases where there is no arrangement for avoiding tax, eg on a merger or takeover.

Post 19 July 2011

For the set off of pre-entry losses on or after 19 July 2011 a pre-entry loss is any allowable capital loss which accrued to the company before it became a member of the group concerned, ie a loss on a disposal which took place before

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