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Income Tax Act 2007

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Changes over time for: Section 127C

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[F1127CExcess loss allocation to partners who are individualsU.K.
This section has no associated Explanatory Notes

(1)Subsection (2) applies if—

(a)in a tax year, an individual (“A”) makes a loss in a UK property business or an overseas property business as a partner in a firm, and

(b)A's loss arises, wholly or partly—

(i)directly or indirectly in consequence of, or

(ii)otherwise in connection with,

relevant tax avoidance arrangements.

(2)No relevant loss relief may be given to A for A's loss.

(3)In subsection (1)(b) “relevant tax avoidance arrangements” means arrangements—

(a)to which A is party, and

(b)the main purpose, or one of the main purposes, of which is to secure that losses of a UK property business or an overseas property business are allocated, or otherwise arise, in whole or in part to A, rather than a person who is not an individual, with a view to A obtaining relevant loss relief.

(4)In subsection (3)(b) references to A include references to A and other individuals.

(5)For the purposes of subsection (3)(b) it does not matter if the person who is not an individual is not a partner in the firm or is unknown or does not exist.

(6)In this section—

  • arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable), and

  • relevant loss relief” means relief under section 118 (carry-forward property loss relief) or section 120 (property loss relief against general income).]

Textual Amendments

F1S. 127C inserted (with effect in accordance with Sch. 17 para. 14 of the amending Act) by Finance Act 2014 (c. 26), Sch. 17 para. 9(3)

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