Trading losses and anti-avoidance

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Summary of trading losses anti-avoidance rules

There are several anti-avoidance rules involving the utilisation of trading losses which are summarised below:

Conditions	Consequences
Major change in nature or conduct of trade of the company, or the company’s activities become small or negligible (without a change in ownership of the company)	Trading losses arising after the change in ownership cannot be relieved against profits arising before the change and losses carried forward cannot be relieved against trading profits or total profits. Relief is lost completely. See below
Post-1 April 2017 change in ownership and major change in the business of the company	Losses eligible for carried forward relief against total profits are not available against post-change of ownership profits, including terminal losses. Relief is lost for five years. See below
Post-1 April 2017 change in ownership, and:	Trading losses available for carried forward relief, including terminal losses, are not available against the gain. Relief is lost for gains arising within five years. See Simon’s Taxes D1.1127
– no gain, no loss transfer within a group or tax neutral transfer

Continue reading

To read the full Guidance note, register for a free trial of Tolley+™

TAKE A FREE TRIAL

Popular Articles

Personal Tax

Transferable tax allowance (also known as the marriage allowance)

Transferable tax allowance (also known as the marriage allowance)What is the transferable tax allowance (marriage allowance)?From 6 April 2015, an individual can elect to transfer 10% of the personal allowance (£1,260) to the spouse or civil partner where neither party is a higher rate or additional

14 Jul 2020 13:52 | Produced by Tolley Read more

Exemption ― insurance ― overview

Exemption ― insurance ― overviewThis guidance note provides an overview of the VAT treatment of insurance products and should be read in conjunction with the Insurance ― specific transactions and Exemption ― insurance ― brokers and agents guidance notes.Is insurance exempt from VAT?Supplies of

Trusts and Inheritance Tax

Bare trusts ― income tax and CGT

Bare trusts ― income tax and CGTThis guidance note explains how trustees of bare trusts are treated for income tax and capital gains purposes. Although a bare trust is, in equity, a type of trust, for both income tax and capital gains tax purposes its existence is transparent. This means that no tax

14 Jul 2020 15:34 | Produced by Tolley Read more

��˾��ҹ��