CTM04900 - Corporation tax: CT loss reform: commencement: note concerning examples

The following examples, at CTM04910 to CTM04970, show when apportionment is necessary, and what types of amounts should be apportioned.

For the purposes of simplicity, unless otherwise stated, in all of the examples below:

  • Apportionment on a time basis has been made by reference to months. In practice, this should normally be made by reference to days.
  • It is assumed that apportioning on a time basis gives a just and reasonable result.
  • The deductions allowance available to groups when calculating the loss restriction has been treated as being nil.
  • It is assumed that all necessary claims have been made to set off losses and other amounts to the full extent possible. This applies for both amounts incurred in and carried forward to the straddling period.
  • NTLR deficits are apportioned only to the extent necessary, as set out above.