CFM6300 - Taxing Loan relationships: anti-avoidance: imported losses: introduction and contents

Introduction

FA96/SCH9/PARA10 is an anti-avoidance provision. It is designed to prevent companies obtaining tax relief for losses that have nothing to do with the UK. For instance, where a company migrates to the UK, Para 10 prevents it obtaining tax relief for losses arising on loan relationships held by it before it migrated to the UK to the extent they relate to such earlier periods. Similarly, where a company 'pregnant' with such losses is purchased by another company (loss-buying), these losses will not be available for group relief.

Contents