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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.7 Loan relationships /Taxation treatment of loan relationship debits and credits / D1.740 Relief for non-trading deficits—pre 1 April 2017 deficits and charities
Commentary

D1.740 Relief for non-trading deficits—pre 1 April 2017 deficits and charities

Corporate tax

The provisions in this article apply, broadly, where a non-trading deficit arose before 1 April 2017. They also apply (pre and post 1 April 2017) where the company is a charity, For the provisions that apply on or after 1 April 2017 to companies other than charities see 'Relief for non-trading deficits—post 1 April 2017 deficits' at D1.739.

Finance (No 2) Act 2017 introduced wholesale reform of the loss carry forward rules for non-trading deficits1 with the stated aim being to simplify the rules and provide more flexibility in how losses carried forward can be relieved.

For ease, the commentary has therefore been broken down into a discussion of the rules that apply for accounting periods commencing on or after 1 April 2017 and those that apply for earlier periods ('Relief for non-trading deficits—post 1 April 2017 deficits' at D1.739), although a lot of the post 1 April 2017 legislation mirrors the pre April 2017 rules.

Where a company's accounting period straddles 1 April 2017, the

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