BIM72645 - Partnerships: loss relief restrictions: non-active partners: example

On 1 April 2004 Z becomes a partner in a general partnership on a non-active basis, introducing capital of £10,000.

Z’s share of the partnership profits and losses is:

Year ended 31 March 2005Loss (£15,000)
Year ended 31 March 2006Loss (£10,000)
Year ended 31 March 2007Profit £10,000
Year ended 31 March 2008Profit £20,000
Year ended 31 March 2009Loss (£75,000)


Z is entitled to sideways relief for losses as follows:

2004/2005£10,000 (a)(unrelieved loss £5,000)
2005/2006Nil (b)(unrelieved loss £10,000 + £5,000 = £15,000)
2006/2007N/A(£10,000 of unrelieved losses brought forward set against trading profits under ITA07/S83)
2007/2008N/A(£5,000 of unrelieved losses brought forward set against trading profits under ITA07/S83)
2008/2009£25,000 (c)


(a) Sideways loss relief restricted to capital contribution at 31 March 2005 (£10,000). The balance of the loss of £5,000 (£15,000 - £10,000) is carried forward.

(b) No sideways loss relief of £5,000 is available as capital contribution at 31 March 2006 (£10,000) does not exceed total sideways relief given for earlier years.

(c) No restriction on sideways loss relief by reference to capital contributions as 2008/09 is not an early year of trading, but £25,000 annual limit applies. The £50,000 balance of the loss can only be carried forward to set against profits of the same trade for later years under ITA07/S83. Losses restricted by the annual limit are not ‘unrelieved losses’ available for sideways loss relief in later years, see BIM72650.