Losses: restriction of loss relief: non-residents
A loss which accrues to a person in a year in which he or she is neither resident nor ordinarily resident* in the United Kingdom does not normally qualify for relief. But where a non-resident is carrying on a business in the UK through a branch or agency, losses are allowable if they accrue on the disposal of branch or agency assets. See CG13550+.
Similarly, a loss accruing to a non-resident company carrying on a trade in the UK through a permanent establishment, on the disposal of assets of the permanent establishment, is an allowable loss, see CG42100+.
- For 2013/14 and subsequent years ordinary residence does not need to be considered.