Commentary

D2.446 Special calculation—Scope

Corporate tax
Corporate tax | Commentary

D2.446 Special calculation—Scope

Corporate tax | Commentary

D2.446 Special calculation—Scope

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414). Prior to 19 July 2011, the rules in this article applied only where the loss buying rules (D2.402–D2.406) did not apply (ie where there was no arrangement for avoiding tax, eg on a merger or takeover).

In specified circumstances, the general calculation as described in D2.443–D2.445 is superseded by a special calculation. The intention of this appears to be to counter the situation where the amount of a loss allocated, under the general calculation, to the post-entry element (and thus outside

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