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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 ...

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