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Corporation Tax Act 2010

Section 66: Relief for losses made in overseas property business

248.This section sets out the rules for relieving losses made in an overseas property business. It is based on section 392B of ICTA.

249.“Overseas property business” is defined in section 206 of CTA 2009. This definition is reproduced in order to avoid the need to cross-refer:


every business which the company carries on for generating income from land outside the United Kingdom, and


every transaction which the company enters into for that purpose otherwise than in the course of such a business.

250.Subsection (3) provides that a loss from an overseas property business may be carried forward and set against future profits of that business. Such profits do not include chargeable gains.

251.Subsection (6) provides that relief is subject to restriction or modification in accordance with provisions of the Corporation Tax Acts. Examples of such restrictions or modifications are to be found in:

  • Section 60 (meaning of “contribution to the LLP”); and

  • Chapter 7 of this Part (write off of government investment in a company).

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