Bank loss restriction: carried forward reliefs outside the restriction: reliefs for new entrant banks – extra information
A banking company’s start-up period runs for five years beginning with the first day a company undertakes relevant regulated activity. A company’s start-up period may be reduced (potentially entirely) under certain circumstances as described in BKM306500.
Reliefs arising during a company’s start-up period are taken to be used before any relevant carried-forward losses (CTA10/S269CF(4)).
A banking company’s start-up period may end part way through an accounting period. Where this happens and a company would carry-forward a relevant relief from the straddling accounting period it will be split into two accounting periods. The amount of relief arising in the split period ending with the start-up period will not be restricted, whilst the amount of relief arising in the later split period will.
The relief is apportioned on a time basis, unless that basis would be unjust or unreasonable, in which case a different method of apportioning the relief can be used.