Part 14Change in company ownership
F1CHAPTER 5AShell companies: restrictions on relief
Restrictions on relief
705CRestriction on debits to be brought into account
1
This section has effect for the purpose of restricting the debits to be brought into account for the purposes of Part 5 of CTA 2009 (loan relationships) in respect of the company's loan relationships.
2
The debits to be brought into account for the purposes of Part 5 of CTA 2009 for—
a
the accounting period beginning immediately after the change in ownership, or
b
any subsequent accounting period,
do not include relevant non-trading debits so far as amount A exceeds amount B.
3
Amount A is the sum of—
a
the amount of those relevant non-trading debits, and
b
the amount of any relevant non-trading debits which have been brought into account for the purposes of that Part for any previous accounting period ending after the change in ownership.
4
Amount B is the amount of the taxable total profits of the accounting period ending with the change in ownership.
5
For the meaning of “relevant non-trading debit”, see section 730.
705DRestriction on carry forward of non-trading deficit from loan relationships
1
This section has effect for the purpose of restricting the carry forward of a non-trading deficit from the company's loan relationships under Part 5 of CTA 2009 (loan relationships).
2
Subsection (3) applies if the non-trading deficit in column 1 of row 4 of the table in section 705F(2) is apportioned in accordance with section 705F to the first notional accounting period.
3
None of that non-trading deficit may be carried forward to—
a
the accounting period beginning immediately after the change in ownership, or
b
any subsequent accounting period.
705ERestriction on relief for non-trading loss on intangible fixed assets
1
This section has effect for the purpose of restricting relief under section 753 of CTA 2009 (treatment of non-trading losses) in respect of a non-trading loss on intangible fixed assets.
2
Relief under section 753 of CTA 2009 against the total profits of the same accounting period is available only in relation to each of the notional accounting periods considered separately.
3
A non-trading loss on intangible fixed assets for an accounting period beginning before the change in ownership may not be—
a
carried forward under section 753(3) of that Act to an accounting period ending after the change in ownership, or
b
treated under that section as if it were a non-trading F2loss on intangible fixed assets for that period.
Pt. 14 Ch. 5A inserted (with effect in accordance with Sch. 13 para. 3 of the amending Act) by Finance Act 2013 (c. 29), Sch. 13 para. 1(3)