CFM64440 - Accounts drawn up in a foreign currency: rates used for translation: change in tax calculation currency: example of carried forward losses

Example of carried forward losses

During the year ended 31 December 2018, a company has a functional currency of US$. During the year ended 31 December 2019, the functional currency of the company changes to sterling.

The taxable results are as follows:

Year ended 31 December 2018 - $12m trading loss
Year ended 31 December 2019 - £2m trading profit
Year ended 31 December 2020 - £20m trading profit

The relevant $/£ exchange rate is the spot rate on 1 January 2019: 1:1.5

The first step is to translate the dollar loss in 2018 into a sterling loss. This would be at the spot rate on 1 January 2019 (1:1.5) and results in a sterling loss of £8m.

As all profits after 31 December 2018 are computed in sterling, the £8m loss would be offset as per normal rules - i.e. £2m offset in 2019 and the remaining £6m offset in 2020. There is no need for any further translations.