HMRC internal manual

Company Taxation Manual

CTM08780 - Corporation Tax: change of ownership: companies with investment business: excess over profits

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

CTA2010/S679 et seq.

Where CTA2010/S677 applies:

  • any profits of the company that relate to an accounting period (or notional accounting period) ending after the change in ownership cannot be reduced by any excess of management expenses, charges and interest that accrued before the change in ownership,


  • the extent to which loan relationship debits and/or non trading loan relationship deficits (for changes in ownership on or after 10 February 2005) can be brought into account in computing the profits of accounting periods that follow the change in ownership is restricted.