BIM75760 - Losses - restriction of relief: Trade losses - income not eligible/losses not eligible

There are certain types of income against which ITA07/S64 relief and ITA07/S72 relief is not available:

1. Before 1 April 2008, no ITA07/S64 or ITA07/S72 relief could be given against interest or dividend income within the scope of ICTA88/S731-735. This anti-avoidance legislation, which was aimed at a form of bond-washing known as “dividend buying” was repealed as obsolete by FA2008.
2. Income from oil operations are excluded from the relief except where the loss arises from those activities (ICTA88/S492 (2). Inspectors should refer such cases to the Large Business Service (Oil and gas sector).

Losses in trade, profession or vocation carried on wholly abroad by a UK resident are relievable against qualifying foreign income only ITA07/S95. Refer to CAR residency for advice on ITA07/S95.