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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
Updated
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Sale of lessor companies and similar arrangements: partnerships: amount of expense - change in ownership of partner company

Section 427 CTA2010

The amount of the expense when there a change in the ownership of a partner company equals the amount of the income.

Section 427 restricts access to losses.

Where the relevant day falls before 21 March 2013 any amount of loss that is derived from the expense is not available to carry back to an earlier accounting period. The amount derived from the expense is identified by treating the expense amount as the final amount deducted.

Where the relevant day falls on or after 21 March 2013 the restriction was extended to prevent any amount of loss carried back from being set against any profits derived from the income amount. The amount derived from the income amount is identified by treating the income amount as the final item added.