Commentary

D8.360 Loss relief generally

Corporate tax
Corporate tax | Commentary

D8.360 Loss relief generally

Corporate tax | Commentary

Loss relief

D8.360 Loss relief generally

An investing company may claim to set an allowable loss on a disposal of shares that qualified for investment relief against its income, provided that the following conditions are satisfied1:

  1.  

    •     the investment relief is not withdrawn in full as a result of the disposal

  2.  

    •     the investing company held the shares continuously from the time they were issued2

  3.  

    •     the disposal is one of the following:

    1.  

      –     a sale made at arm's length for full consideration

    2.  

      –     a distribution during the dissolution or winding up of the issuing company, or

    3.  

      –     a

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