Part 9Leasing plant or machinery

Chapter 4Sales of lessors: leasing business carried on by a company in partnership

Qualifying changes of ownership in relation to partner company

427No carry back of the expense

(1)This section applies if the notional business carried on by the company is a trade carried on wholly or partly in the United Kingdom the profits of which are chargeable to corporation tax under Chapter 2 of Part 3 of CTA 2009 (trading income).

(2)No relief is to be given as a result of section 37(3)(b) (relief for trade losses against total profits of earlier accounting periods) in respect of so much of any loss as derives from the expense.

(3)For the purpose of determining how much of a loss derives from the expense, the loss is to be calculated on the basis that the expense is the final amount to be deducted.