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Corporation Tax Act 2010

Section 704: Company carrying on UK property business

2184.This section restricts relief for UK property losses in cases in which this Chapter applies. It is based on section 768D of ICTA.

2185.Subsections (1) to (3) lay down the conditions for the section to apply.

2186.Subsection (4) states the purpose of the section. In subsection (4), “the company” has the meaning given by subsection (1).

2187.Subsection (5) deems the accounting period in which the change of ownership occurs to be two separate accounting periods. The profits or losses of the actual accounting period must then be apportioned to the two notional accounting periods in accordance with subsections (6) and (7).

2188.Subsections (8) and (9) set out the consequences of this apportionment.

2189.Subsection (10) defines “major change in the nature or conduct of a trade or UK property business”.

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