Commentary

D7.553 Restricted relief for non-BLAGAB losses

Corporate tax
Corporate tax | Commentary

D7.553 Restricted relief for non-BLAGAB losses

Corporate tax | Commentary

D7.553 Restricted relief for non-BLAGAB losses

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

Dealing with the simpler ring-fence first, non-BLAGAB allowable losses may not be deducted from the policy holders' share of the BLAGAB chargeable gains1 with the result that losses arising on assets of the shareholders' fund may be relieved only against the shareholders' share of BLAGAB gains. Thus the policy holders' interest in the profits of the fund is not reduced by the economic activities of the shareholders.

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