SCHEDULES

SCHEDULE 4Relief for carried-forward losses

PART 9Tax avoidance

Deduction buying

92

(1)

Section 730C of CTA 2010 is amended as follows.

(2)

In subsection (2)—

(a)

omit “or” at the end of paragraph (a),

(b)

after paragraph (b) insert“, or

(c)

Chapter 3 of Part 5A (group relief for carried-forward losses).”

(3)

In subsection (3), for “A deductible amount that meets conditions A and B” substitute “ In the case of a relevant claim within subsection (2)(a) or (b), a deductible amount that meets conditions A and B (a “restricted deductible amount”) ”.

(4)

After subsection (3) insert—

“(3A)

A relevant claim within subsection (2)(c) may not be made in respect of a loss or other amount which has been carried forward under any provision mentioned in paragraphs (a) to (e) of section 188BB(1), so far as that amount is made up of an amount which was (in a previous accounting period) a restricted deductible amount.”

(5)

In subsection (4)—

(a)

for “subsection (3) does” substitute “ subsections (3) and (3A) do ”, and

(b)

for “the claim” substitute “ or as a result of, the claim concerned ”.

(6)

After subsection (7) insert—

“(7A)

For the purposes of determining how much of an amount carried forward as mentioned in subsection (3A) is made up of an amount which was (in a previous accounting period) a restricted deductible amount, assume that in previous accounting periods amounts have been brought into account as deductions (see section 730B(2)) in the order that results in the greatest amount being excluded by subsection (3A).”

(7)

The amendments made by this paragraph do not have effect if the relevant day (as defined in section 730B(1) of CTA 2010) is before 1 April 2017.