Commentary

D7.457 Ring-fencing of losses – Restricted relief for non-BLAGAB losses

Corporate tax
Corporate tax | Commentary

D7.457 Ring-fencing of losses – Restricted relief for non-BLAGAB losses

Corporate tax | Commentary

D7.457 Ring-fencing of losses – Restricted relief for non-BLAGAB losses

Dealing with the simpler ring-fence first, non-BLAGAB allowable losses may not be deducted from the policyholders' share of the BLAGAB chargeable gains1with the result that those losses may be relieved only against the shareholders' share of BLAGAB gains. Thus the policyholders' interest in the profits of the business is not reduced by the economic activities of the shareholders.

The shareholders' share of BLAGAB chargeable gains depends on whether there is an I-E profit for the accounting period in question.

If there is such a profit the shareholders' share is calculated by:

  1.  

    (a)    

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