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SCHEDULES

SCHEDULE 10U.K.Corporation tax relief for carried-forward losses

Transferred tradesU.K.

26U.K.CTA 2010 is amended as follows.

27U.K.In section 357JI (Northern Ireland losses: transfers of trade without a change of ownership) in subsection (2) for the words from the beginning to “that section” substitute “ Sections 943A to 944C (which modify the application of Chapter 2 of Part 4) have effect as if the references in those sections ”.

28U.K.In section 676 (disallowance of trading loss on change in ownership of company: company reconstructions)—

(a)in subsection (2) for the words from “section 944(3)” to “successor company)” substitute “ Chapter 1 of Part 22 ”,

(b)in subsection (4)(a) after “45” insert “ , 45A, 45B, 303B, 303C or 303D ”, and

(c)in subsection (4)(b) for “944(3)” substitute “ Chapter 1 of Part 22 ”.

29U.K.In section 676AF (restriction on use of carried-forward post-1 April 2017 trade losses)—

(a)the existing provision becomes subsection (1), and

(b)after that subsection insert—

(2)A loss made by another company (“the predecessor company”) in an accounting period beginning before the change in ownership may not be deducted from affected profits of an accounting period ending after the change in ownership under any of the provisions mentioned in paragraphs (a) to (c) of subsection (1) (as applied by virtue of Chapter 1 of Part 22 (transfers of trades)).

30U.K.In section 676BC (disallowance of relief for trade losses)—

(a)in subsection (1) omit “by the company”,

(b)in subsection (4), in the words before paragraph (a), after “made” insert “ by the company ”, and

(c)after subsection (4) insert—

(5)A loss made by another company (“the predecessor company”) in an accounting period beginning before the change in ownership may not be deducted as a result of section 45A, 45F or 303C (as applied by Chapter 1 of Part 22 (transfers of trades)) from so much of the total profits of an accounting period of the company ending after the change in ownership as represents the relevant gain.