Corporation Tax Act 2010 (c. 4)

Schedules

SCHEDULE 2 U.K. Transitionals and savings etc

Part 4 U.K. Loss relief (other than share loss relief)

Loss relief against miscellaneous income: Case VI losses under ICTA U.K.

25 (1) This paragraph applies to any loss made by a company in a transaction if— U.K.

(a) the transaction was of such a nature that, if any profits had arisen from it, the company would have been liable under ICTA to corporation tax in respect of the profits under Case VI of Schedule D (see section 18 of ICTA) for an accounting period ending before 1st April 2009, and

(b) the transaction—

(i) did not fall within section 34, 35 or 36 of ICTA (lease premiums etc), and

(ii) was not a disposal made after 31 March 2007 to which Chapter 5 of Part 17 of that Act (offshore funds) applied.

(2) So far as relief for the loss has not been previously given, the loss is to be treated as a loss to be carried forward and relieved in accordance with section 91.