Part 14Change in company ownership

Chapter 4Company with investment business: restrictions on relief: asset transferred within group

Restrictions on relief

697Restriction on the 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

But this section applies only if, in accordance with the relevant provisions and section 702, an amount is included in respect of chargeable gains or, as the case may be, non-trading chargeable realisation gains in the total profits of the accounting period of the company in which the relevant gain accrues or arises.

3

Subsection (4) applies if the non-trading deficit in column 1 of row 5 of the table in section 702(2) is apportioned in accordance with section 702(2) to the first notional accounting period.

4

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.