OT21056A - Corporation Tax Ring Fence: Losses and Group Relief: Losses Carried Forward: Losses arising after 1 April 2017: Decommissioning losses arising after 1 April 2017

CTA10/S45B

Decommissioning losses, to the extent that they are not used by the company in the loss-making AP, carried back to set against the profits of previous APs, or surrendered as group relief are carried forward under CTA10/S45B(2). Relief for these losses is not restricted under CTA10/PART7ZA (CTA10/S304(7)).

Losses carried forward under CTA10/S45B can only be set against profits arising from the same trade in subsequent APs and cannot be set against the total profits of the company. Losses carried forward under CTA10/S45B are also not available to be surrendered as group relief.

Relief under CTA10/S45B is given automatically in the next AP in which a profit is made in the ring fence trade, unless the company makes a claim under CTA10/S45B(5) to not use the losses. Any such claim must be made within two years of the end of the AP in which the company wishes to disclaim the use of the losses.