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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Corporation Tax: change of ownership: companies with investment business: restriction for accounting periods ending on or after 1 April 1996 (S692)

CTA2010/S692

Where CTA2010/S692 applies, no deduction is to be made under CTA2009/S1219 for:

  • any management expenses or capital allowances, or
  • any charges,

attributed to the actual or notional accounting period ending before or with the change in ownership from an amount of total profits equal to the amount that represents the relevant gain.

There is also a restriction on the debits to be brought into account in computing the company’s debits from loan reltionships. The debits that may be subject to restriction are those listed in CTM08850. They are not to be brought into the debits from loan relationships computation to the extent, if any that they exceed the total profits:

  • as reduced, if the relevant gain accrued in that period, by an amount equal to the relevant gain, and
  • after making all deductions and giving all reliefs, other than any reduction under CTA2009/S461.

For changes in ownership on or after 10 February 2005 any non trading loan relationship deficit which is attributed to the actual or notional accounting period ending before or with the change in ownership is not carried forward to an actual or notional accounting period after the change in ownership.