Commentary

D2.455 Record keeping

Corporate tax
Corporate tax | Commentary

D2.455 Record keeping

Corporate tax | Commentary

Other restrictions on pre-entry losses—Administration

D2.455 Record keeping

The rules in this article apply only where the loss buying rules (D2.402) 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.

In view of the provisions regarding the order of set-off of losses against gains1, it is clearly necessary for every company to keep records of the composition of its capital losses carried forward to the first accounting period ended after 15 March

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