Part 1 Amendments of CTA 2010

SCHEDULE 3 Tax Avoidance Involving Carried-Forward Losses

Section 33

Part 1 Amendments of CTA 2010

1

In CTA 2010, after Part 14A insert—

“Part 14B
Tax Avoidance Involving Carried-Forward Losses
730·¡Ìý°¿±¹±ð°ù±¹¾±±ð·É

(1)     This Part makes provision restricting the circumstances in which a company may make a deduction in respect of a relevant carried-forward loss.

(2)     For the meaning of “relevant carried-forward lossâ€, see section 730F.

730F Meaning of “relevant carried-forward lossâ€

(1)     In this Part “relevant carried-forward loss†means any of the following—

(a)     a carried-forward trading loss (see subsection (2)),

(b)     a carried-forward non-trading deficit (see subsection (3)),

(c)     any carried-forward management expenses (see subsection (4)).

(2)     “Carried-forward trading lossâ€, in relation to a company and an accounting period, means a loss in a trade of the company which is carried forward from a previous accounting period under section 45 (carry forward of trade loss against subsequent trade profits).

(3)     “Carried-forward non-trading deficitâ€, in relation to a company and an accounting period, means a non-trading deficit which the company has from its loan relationships under section 301(6) of CTA 2009 and which is carried forward from a previous accounting period under section 457 of that

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