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HMRC internal manual

Business Income Manual

Business Income Manual: Computing the amount to assess: Mixed Membership Partnerships: Excess loss allocation: Transitional Provisions

Paragraph 14, Schedule 17 FA 2014

These rules apply for losses made in 2014-15 and later years.

There are transitional provisions that apply if a loss arises in a period of account that begins before 6 April 2014 and ends on or after that date.

The excess loss allocation rules apply to the period from 6 April 2014; they do not apply to the period up to 5 April 2014.

In these cases, the loss is to be apportioned on a time basis between the period up to 5 April 2014 and the period from 6 April 2014.

If allocation by time basis produces a result that is unjust or unreasonable, then the loss is to be allocated to the periods on a just and reasonable basis.