Of key importance in quantifying losses available to partners is establishing whether a 'partnership' loss can actually be utilised by the partners concerned. This is because, once a partnership loss has been allocated to a partner, there are several provisions that operate to restrict 'sideways' loss relief, the main one being by reference to capital contribution of the partner — see B7.522.
Once the restriction by reference to capital contribution has been applied, there is a further limit (in the form of an overall cap) to sideways and capital gains relief1. This cap is currently set at £25,000 and applies to limited and non-active partners (as defined in B7.522). The limit does not applt to corporate partners. This amount may be modified by regulations2.
The
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:12