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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Trade losses - restriction of relief: income not eligible/losses not eligible

There are certain types of income against which S64 Income Tax Act 2007 (ITA 2007) relief and S72 ITA 2007 relief is not available:

  1. Under S80 ITA 2007, income from oil operations is excluded from the relief except where the loss arises from those activities. Officers should refer such cases to the Large Business Service (Oil and gas sector).
  2. Under S95 ITA 2007, losses in a trade, carried on wholly abroad by a UK resident, are relievable against qualifying foreign income only. Refer to Specialist PT (Residency) for advice on Section 95.

For restrictions on loss relief on farming activities, see BIM85605 onwards.