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HMRC internal manual

Company Taxation Manual

Corporation Tax: loss-buying: advising taxpayers

If a company proposes a course of action and asks for confirmation as to whether CTA10/S673 will apply, see CTM00505 on giving advice.

Most enquiries are about CTA10/S673 (4) - major change in the nature or conduct of a trade - CTM06370). It would not be appropriate to give an advance assurance about legislation which provides a three-year period of review of the nature and conduct of the company’s trade. The enquirer’s attention should also be drawn to SP10/91 (CTM06380).