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HMRC internal manual

Banking Manual

Bank loss restriction: calculation of carried-forward reliefs available: effect on the availability of other reliefs

CTA10/S269CD (pre-1 April 2017), S269ZF (post-1 April 2017)

When the banking company performs its tax calculation the normal ordering rules will still apply; for example group relief will only be available against profits remaining after all other reliefs of the current period and previous periods.

Under the restriction, however, the relevant carried-forward losses can be effectively displaced by other relief.  This means that a company under the restriction may potentially be able to claim more of some reliefs, because the profits against which they are set will be assumed not to have been reduced by any of the relevant carried-forward losses. 

Any other amounts deducted when calculating relevant profits will reduce the figure of relevant profits used for calculating the available amount of relevant carried-forward relief.  Another example is qualifying charitable donations which would normally be last of all but for group relief and relief carried back (CTA10/S189; CTM09100).

BKM304850 has an example of the effect of the bank loss restriction calculation on the availability of group relief.