OT66080 - Transferable tax history - TTH allocation on a loss carry back - Allocation of the Total activated TTH amount

Having calculated the Total activated TTH amount for the first loss making period (OT66020) or any subsequent loss-making period (OT66030) as the case may be, that amount must then be allocated to pre-transaction accounting periods of the purchaser for which there is an unused transferred profits amount.

An unused transferred profits amount is a transferred profits amount that has not had a decommissioning loss set against it in accordance with FA19\Sch15\Para25.

The amount of the total activated TTH amount that must be allocated to the most recent pre-transaction accounting period for which there is an unused transferred profits amount is the lower of the unused transferred profits amount for that period, and the total activated TTH amount held by the purchaser.

If the unused transferred profits amount for the most recent period is lower than the total activated TTH amount held by the purchaser, the purchaser then allocates the balance of the total activated TTH amount to the next most recent pre-transaction accounting period for which there is an unused transferred profits amount, again capped at the lower of the balance of the total activated TTH amount and the unused transferred profits amount.

This process is repeated for earlier accounting periods, until the whole of the total activated TTH amount has been allocated, or there are no unused transferred profits amounts left in any pre-transaction accounting periods.

Once the allocations have been made as set out above, the purchaser may set a decommissioning loss against the activated TTH in accordance with FA19\Sch15\Para25 (see OT63040).