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HMRC internal manual

Guidance on Real Estate Investment Trusts

From
HM Revenue & Customs
Updated
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Entry to the regime: effects of entry: trading and other losses from pre-entry periods

The table below sets out the position for utilising losses etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See GREIT03100 for descriptions of terms used below and for Table 1: capital losses

Table 2: trading and other losses etc

Description Type of loss etc Can be used against
     
Qualifying UK property business Property loss No carry forward since business ceases at entry (section 541(4) CTA 2010)
Other UK property business Property rental loss (section 392A(2) ICTA) Profits of the residual business
Trade Trading loss (section 393A ICTA) Trading profits of the same trade included in the residual business
Qualifying overseas property business Overseas property loss No carry forward since business ceases at entry (section 541(4) CTA 2010)
Other overseas property business Overseas property loss (section 392B ICTA) Overseas profits of other overseas property business included in the residual business
Other overseas income Overseas trading loss (section 393A ICTA) Overseas profits from same source included in the residual business
Other chargeable income section 396 ICTA Other chargeable profits included in the residual business

 

 

See GREIT03100 and GREIT03110 for Tables 1 and 3: capital losses and other expenses etc.