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HMRC internal manual

Corporate Intangibles Research and Development Manual

Land Remediation Relief: Tax Credit: Qualifying land remediation loss - unrelieved losses

FA01/SCH22/PARA14 (4)

CTA09/S1153 (1)

The unrelieved trading loss, or property business loss, of a company is the amount of the loss for that accounting period reduced by:

  • the amount of any claim that could be made, whether or not actually made, to set the loss against other profits of the same accounting period (ICTA88/S392A (1) and ICTA88/S393A (1)(a)), and
  • any other relief claimed by the company in respect of the loss for that accounting period, e.g. losses set off against profits of an earlier accounting period (ICTA88/S393A (1)(b)) and losses surrendered to group or consortium members (ICTA88/S403 (1)).

The following losses are ignored in calculating the amount of unrelieved loss:

  • trading losses, or property business losses, brought forward from an earlier accounting period (ICTA88/S393 (1)) and ICTA88/S392A (2), or
  • any trading losses carried back from a later accounting period, (ICTA88/S393A (1)(b)).