Dealing with HMRC – guidance

Restriction on brought forward reliefs in the UK banking sector - technical note

This technical note provides the detail as to how the proposed legislation will operate.



On 3 December 2014 the Chancellor of the Exchequer announced that the government will introduce legislation in the Finance Bill 2015, which will restrict the proportion of banks’ annual taxable profit that can be offset by certain carried forward reliefs to 50%. The restriction will apply to carried forward of trading losses, non-trading loan relationship deficits, and management expenses. The restriction will take effect from 1 April 2015 and will only apply to relevant reliefs accruing prior to this date.