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HMRC internal manual

Company Taxation Manual

Corporation Tax: loss buying: provisions introduced in F(No 2)A 2017


Chapters 2A to 2E extend pre-existing rules found in CTA10/PART14 and CTA10/PART14A to counter loss buying in a number of circumstances.

These chapters only apply where there has been a change in company ownership on or after 1 April 2017. Their effect is to restrict the ways in which that company can use losses and other amounts incurred before the change.

Chapter 2A extends the restrictions on relief where there is a major change in the business of a company (CTM06740) in addition to the change in ownership.

Chapter 2B and Chapter 2D (CTM06780) extend restrictions on relief in situations where an asset has been transferred to the company following a change in ownership.

Chapter 2C restricts group relief for carried-forward losses (CTM06810) following a change in ownership.

Chapter 2E (CTM06850) restricts relief for trading losses in situations where there has been a change in ownership and a transfer of trade.