Reform of Corporation Tax loss relief: amended draft guidance on commencement provisions
HMRC is amending its draft guidance on the Corporation Tax loss relief commencement provisions.
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HMRC has updated its draft guidance explaining the Corporation Tax loss relief commencement provisions in advance of transferring this guidance to the Company Taxation Manual.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)
A first tranche of guidance was published on 31 July 2017.
A second tranche of guidance was published on 6 November 2017.
Guidance on administrative requirements was published on 8 November 2018.
A consultation on the reforms to Corporation Tax loss relief has been carried out.
A tax information and impact note has also been published.
Last updated 9 November 2018 + show all updates
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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).
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First published.