Commentary

D7.554 Restricted relief for BLAGAB losses

Corporate tax
Corporate tax | Commentary

D7.554 Restricted relief for BLAGAB losses

Corporate tax | Commentary

D7.554 Restricted relief for 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.

The government's original intention was to deny relief for BLAGAB losses against non-BLAGAB gains but this restriction was removed during the consultation process that took place between the publication of the draft legislation and its subsequent enactment in FA 2003. One difficulty was establishing the precise proportion of brought forward losses that equated to the shareholders' share because this would change on a year by year basis. The

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