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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Corporation Tax: trading losses - relief against total profits: no relief for losses of a company that carries on a trade wholly outside the United Kingdom

CTA10/S37 (5)

CTA10/S37 (5) provides that set-off of relief against profits (CTM04505) is not allowed in any circumstances if the company carries on a trade wholly outside the United Kingdom .