Corp Tax - Chapter 15 Flashcards
Non trading losses CY claim
Whole or part of the deficit from any profits
NTLR losses before or after Trading Losses
Before
Carry back claim NTLR lower of:
Amount of deficit not subject to CY Claim (CY claim does not need to be made first)
Non trading profits of the earlier accounting periods.
Claim date for Carry Back
Two years after end of deficit period
Carry forward relief
Normal restrictions apply - max 50%
Relief is not automatic - claim within two years.
Non trading IFAs - CY, CB and CF
CY - Against total profits, two years of end of loss period.
CB - Not allowed
CF - carry the loss forward and treat the loss as a non-trading IFA loss in the next accounting period. Whole or Part…
Capital losses
CY - Not available against other income
CB - Not allowed
CF - Against CG
CF - Capital losses anti avoidance
There is a targeted anti-avoidance provision to prevent companies entering into arrangements on or after 29 October 2018 to take advantage of the unrestricted offset of brought forward losses incurred before 1 April 2020.
If the main purpose, or one of the main purposes, of such arrangements is to obtain an increased amount of loss relief on the basis that the loss restriction does not apply to losses incurred before 1 April 2020, then the company is only permitted to claim a deduction for 50% of losses incurred as a result of the arrangements in subsequent accounting periods (without the benefit of the deductions allowance).
Excess management expenses before or after QCD and loss claims
Before
Definition of excess management expenses.
Expenses > Profit for period.
Excess Management CY Claim
N/A
Excess Management CB Claim
N/A
Excess Management CF Claim
Offset against future total profits
Claim is not automatic and claim within 2 years.
Compliance with CF
A company must specify the amount of its deductions allowance in its corporation
tax return.
The return must also specify the allocation of the deductions allowance between
different types of profits if the loss carried forward can only be used against certain
kinds of profits, eg capital losses set against chargeable gains only.
The way in which the deductions allowance increases the amount of carried
forward loss relief that a company is entitled to operates in the same way for all types of loss.