Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Application of the corporate capital loss restrictions

12 May 2020 / Mark Baycroft , Imran Umarji
Issue: 4743 / Categories: Comment & Analysis
20432
It’s a squeeze

Key points

  • Corporate capital loss restriction legislation introduced by Finance Bill 2020.
  • The corporate income loss restriction limited relief to 50% of profits.
  • A £5m deduction allowance applies but this must be divided between the capital and income loss regimes.
  • A new ‘relevant maximum’ is introduced for carried-forward capital losses.
  • The steps to calculate the relevant profits and allowable relief.
  • Accounting periods straddling 1 April 2020 must be split.
  • SMEs may find their deduction allowance is used by larger group members.

Finance Bill 2020 Sch 3 contains the draft legislation (tinyurl.com/s79cewo) for the corporate capital loss restriction (CCLR). This should not come as a shock to most given that the government’s intention to introduce these rules was announced ...

Only subscribers may read the full article

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
back to top icon