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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Corporation Tax: trading losses: general: relief for losses carried forward: inclusion of interest & dividends in trading income

CTA10/S46, CTA09/S1285, CTA09/Part9A

A company may be unable to use loss relief under CTA10/S45 because it has insufficient trading income. If so, interest or dividends which would have been treated as trading receipts but for the fact that they are charged to CT under other provisions may be included in trading income. For interest and dividends generally see BIM40800+.

This extension of the meaning of trading income applies only to dividends and interest within the charge to CT. It does not apply to dividends from UK companies because such dividends are not chargeable to CT. However the extension does apply to building society interest received. Whether or not bank deposit interest can be treated as trading income for the purposes of the extension is covered in BIM40801.