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HMRC internal manual

International Manual

Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Limitations on scope of ICTA88/SCH24/PARA9

Claims under ICTA88/SCH24/PARA9 are competent only in respect of trading losses (or charges treated as losses). No relief is due in respect of management expenses brought forward from accounting periods prior to the first period for which an apportionment falls to be made (CTA09/S1219 and CTA09/S1221).