Commentary

D7.4109 Unrelieved losses at transition

Corporate tax
Corporate tax | Commentary

D7.4109 Unrelieved losses at transition

Corporate tax | Commentary

D7.4109 Unrelieved losses at transition

The rules in this division apply for accounting periods beginning on or after 1 January 2013. For accounting periods beginning before 1 January 2013 see Division D7.5.

Because the pre-2013 regime taxed the profits on the different categories of business separately, so losses on category could be carried forward only for offset against profits on the same type of business. Following the merging of permanent health insurance ('PHI') into non-BLAGAB business, it was recognised that streaming losses carried forward over transition was impractical and imposed a considerable compliance burden for little Exchequer benefit. The government therefore took the welcome step of simplifying the transition by effectively

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