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Chapter CTM04840

Document Cited authorities 1 Cited in Related
Vincent
Published date16 April 2016
Record NumberCTM04840
CourtHM Revenue & Customs
IssuerHM Revenue & Customs
CTA09/S463A to S463I, CTA10/S45A to S45H

The loss relaxation applies for carried-forward losses sustained on or after 1 April 2017.

Five types of loss are affected. These are trade losses, non-trading loan relationship deficits (NTLRDs), non-trading losses on intangible fixed assets (NTLIFAs), management expenses and UK property business losses.

The 1 April 2017 commencement date means that the rules applying to carried-forward losses depend partly on whether they were sustained before or after that date. Companies should make sure that their records reflect this and keep pre- and post-1 April 2017 losses separate, to avoid mistakes in their returns.

Trade losses and NTLRDs

In most cases, trade losses and NTLRDs sustained from 1 April 2017 can be carried-forward and set against total profits of the company (CTA09/S463G, CTA10/S45A). These losses may also be available for group relief for carried-forward losses (CTM82000).

However, companies continue to be more limited in the way they can use losses sustained before 1 April 2017 and certain other losses sustained after that date.

The following trading losses carried-forward can only be deducted from profits of the same trade, and cannot be surrendered as group relief for carried-forward losses:

  • Trading losses sustained before 1 April 2017,
  • Trading losses sustained on or after 1 April 2017 in certain particular circumstances, for example where the trade has become small or negligible (CTA10/S45A to 45E).

The following carried-forward NTLRDs can only be deducted from non-trading profits and cannot be surrendered as group...

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