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HMRC internal manual

Corporate Intangibles Research and Development Manual

Core computational rules: CT computation: intangible assets not used for a trade or property business: set-off of non-trading loss against total profits


Where the aggregation of non-trading debits and credits described in CIRD13530 results in a loss (a ‘non-trading loss’) a company may make a claim to set off all or part of that loss against its total profits for the accounting period in which the loss arises.

The claim must be made within two years of the end of that accounting period or within such period as the Inland Revenue allow. The approach in CTM90610 should be applied to claims made outside the two year time limit.

Subject to that, the general rules for claims under CT self-assessment described in CTM90600 onwards apply.