BIM72630 - Partnerships: loss relief restrictions: active LLP members: example
Y becomes an active member of an LLP on 6 April 2007,
introducing capital of £100,000 into the LLP on that date. The
LLP carries on a trade.
Y’s share of the LLP’s trading loss is as
follows, and he claims relief under ITA07/S64 for those losses to
be set against his other income:
| Year ended 5 April 2008 | £60,000 |
| Year ended 5 April 2009 | £60,000 |
Y is only entitled to set ITA07/S64 relief against his other
income or gains as follows:
| 2007/08 | £60,000 | (unrelieved capital contribution £40,000) |
| 2008/09 | £40,000 | (total relief limited to capital contribution of £100,000; unrelieved loss £20,000) |
Unless Y makes a further capital contribution in a later
year, the unrelieved balance of the loss for 2008/09 (£20,000)
will only be available to be carried forward and set against
Y’s share of the LLP’s profits from the same trade for
later years.
Guidance on giving sideways loss reliefs for unrelieved
amounts if further capital contributions are made is at
BIM72635.
