CTM07505 - Corporation Tax: tax avoidance involving carried-forward losses: overview
CTA10/Part14B
CTA10/Part 14B is an anti-avoidance rule introduced by Finance Act 2015 for the purposes of calculating the profits of accounting periods beginning on or after 18 March 2015. It applies to arrangements that seek to gain a corporation tax advantage by gaining access to certain carried-forward reliefs and 바카라 사이트˜refreshing바카라 사이트™ them into more versatile in-year deductions known as corporate loss refreshing. CTM07510 describes loss refreshing, and CTM07550 has some examples.
The rule restricts the circumstances in which a company may make a deduction in respect of a 바카라 사이트˜relevant carried-forward relief바카라 사이트™. CTM07515 identifies these reliefs, and CTM07530 describes the new deductions covered by the rule.
Where the five conditions CTM07520 are met, the company will not be able to use its carried-forward reliefs against profits of the arrangement.
The rules apply to arrangements entered into at any time, but the denial of carried-forward loss relief will only have effect for accounting periods beginning on or after 18 March 2015. Where an accounting period straddles that date, it is notionally split into two for the purposes of calculating the company바카라 사이트™s taxable total profits under the restriction CTM07545.