»Ê¹ÚÌåÓýapp

FA15/Sch3/Part 2 and F(No 2)A 2017/Sch4/Part12/Para190

»Ê¹ÚÌåÓýapp effect in CTA10/s730G(10) applies in accounting periods beginning on or after 18 March 2015 for carried-forward trading losses, non-trading loan relationship deficits and management expenses. For accounting periods beginning on or after 1 April 2017 this is extended to carried-forward UK property business losses and non-trading losses on intangible fixed assets.

Where the rules apply to a company with an accounting period straddling 18 March 2015 or 1 April 2017, that period will be treated as two separate accounting periods for the purposes of calculating the company’s taxable total profits, and the restriction on relevant carried-forward amounts will apply in the split period treated as commencing 18 March 2015 or 1 April 2017.

»Ê¹ÚÌåÓýapp default is a split on a time basis in accordance with CTA10/s1172, unless that basis is unjust or unreasonable.

This treatment will apportion any profit for the whole accounting period into a profit in the two periods. It is not possible to apportion on a basis that turns a profit for the whole period into a loss in one period and a profit in the other.

»Ê¹ÚÌåÓýapp split applies only so far as it is necessary for the purposes of the restriction.

When arrangements were entered into

»Ê¹ÚÌåÓýapp legislation will apply to tax arrangements entered into at any time. So if a company entered an arrangement prior to 18 March 2015 or 1 April 2017, but with an ongoing effect that continued beyond that date, then the rules would apply to that arrangement with effect commencing as described above.