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HMRC internal manual

Banking Manual

Bank loss restriction: carried forward reliefs outside the restriction: reliefs carried-back from later periods

Accounting periods from 1 April 2015 to 31 March 2017 (CTA10/S269CD)

The calculation of relevant profits does not include any of the following reliefs carried-back from later periods (CTA10/S269CD(2)(b) to (d)):

  • Relief under CTA10/S37(3)(b) for a trading loss made in an accounting period after the current period
  • Relief under section CAA01/S260(3) for excess capital allowances on special leasing of plant or machinery from an accounting period after the current period
  • Relief under CTA09/S459(1)(b) for a non-trading loan relationship deficit  from an accounting period after the current period.

This means that the company can claim these reliefs against any profits remaining after the restriction has been applied without needing to recalculate the amount of relevant profits.

 Accounting periods from 1 April 2017 (CTA10/S269ZF)

The following amounts are not deducted from the company’s modified total profits (BKM305200) when it calculates it’s qualifying trading and non-trading profits (BKM305400):

  • Deductions for trading losses carried back from a later accounting period under CTA10/S37,
  • Deductions for trading losses carried forward to a terminal period, under CTA10/S45F,
  • Deductions for excess capital allowances for special leasing carried back from a later accounting period under CAA2001/S260(3), and
  • Deductions for non-trading loan relationship deficits carried back from a later accounting period under CTA09/S463E.

This means that the company can claim these reliefs against any profits remaining after the restriction has been applied without needing to recalculate the amount of relevant profits.