Version Superseded: 16/11/2017
Point in time view as at 01/04/2010. This version of this provision has been superseded.
Corporation Tax Act 2010, Section 674 is up to date with all changes known to be in force on or before 04 March 2025. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
(1)In calculating the company's taxable total profits of an accounting period beginning before the change in ownership, no relief may be given under section 37 or 42 (relief for trade losses) for a loss made by the company in an accounting period ending after the change in ownership.
(2)No relief may be given under section 45 for a loss made by the company in an accounting period beginning before the change in ownership by carrying forward the loss to reduce the profits of a trade of an accounting period ending after the change in ownership.
(3)For the purposes of this section and section 675—
(a)the accounting period in which the change in ownership occurs is treated as two separate accounting periods, the first ending with the change and the second consisting of the remainder of the period, and
(b)the profits or losses of the accounting period are apportioned to the two periods.
(4)The apportionment under subsection (3)(b) is to be made on a time basis according to the respective lengths of the two periods.
(5)But if that method of apportionment would work unjustly or unreasonably in any case, such other method is to be used as is just and reasonable.
(6)In subsection (2), “profits of a trade” includes interest or dividends treated as profits of a trade under section 46.
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