Part 13Tax avoidance
Chapter 5Avoidance involving trading losses
Individuals in partnership claiming relief for licence-related trading losses
807Supplementary provision relating to calculation in section 806
1
This section applies for the purposes of section 806.
2
For the purposes of Step 1, the amount of a loss made in a tax year that relates to the licence is so much of the loss in the tax year as derives from expenditure incurred in the trade in exploiting the licence.
3
The amount of the loss that derives from such expenditure is determined on a just and reasonable basis.
4
For the purposes of Step 1, a loss is a claimed loss if the individual has claimed sideways relief or capital gains relief for the loss.
5
For the purposes of Step 2, the amount of profits made in a tax year that relates to the licence is so much of the individual's profits from the trade in the tax year as derives from income arising from an agreement related to or containing the licence.
6
The amount of the profits that derives from such income is determined on a just and reasonable basis.