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HMRC internal manual

Business Income Manual

restriction of relief: no sideways relief for tax-generated losses


S74ZA Income Tax Act 2007 (ITA 2007)

S74ZA ITA 2007 is an anti-avoidance measure which denies sideways loss relief for tax-generated losses made by a person (sole trader, partner, trustee) in a trade, profession or vocation. It applies to losses from relevant tax avoidance arrangements entered into on or after 21 October 2009. See BIM85762.

This provision replaces the previous rule denying sideways loss relief for tax-generated losses made on or after 12 March 2008 in a trade, but not profession or vocation, carried on by an individual in a non-active capacity, see BIM85765. It also replaces the previous bar on sideways loss relief for tax-motivated losses in a trade of dealing in commodity futures.