HMRC has updated its draft guidance explaining the Corporation Tax loss relief commencement provisions in advance of transferring this guidance to the Company Taxation Manual. The legislation is included in Part 12 of Schedule 4 to the Finance (No. 2) Act 2017.
The guidance has been amended to reflect comments received on:
the meaning of apportionment
the commencement provisions resulting in no restriction to carried-forward losses
the commencement provisions resulting in a restriction to Part 5 Corporation Tax Act 2010 relief (group relief)
cases where there is an adjustment under Part 10 Taxation (International and Other Provisions) Act 2010 (corporate interest restriction)
The guidance has been updated to reflect comments about apportionment, carried-forward losses, group relief and adjustments under Part 10 Taxation (International and Other Provisions) Act 2010 (corporate interest restriction).