LAM15140 - Excess expenses, losses and deficits:  Set-off Long-term Business Fixed Capital property business losses

Any property income loss arising from property assets in Long-term Business Fixed Capital is treated as a “normal” property loss. See PIM4230.

In summary, the loss:

  • must be first set against the shareholders’ share of total profits of the period;
  • can then surrendered as group relief in the period;
  • carried forward: losses incurred before 1 April 2017 are set against the shareholders’ share of total profits of that period;
  • carried forward: losses incurred on or after 1 April 2017 can be:
    • set against the shareholders share of total profits;
    • surrendered as group relief

Set-off of carried forward property business losses is subject to the loss restriction rules (LAM15200).