INTM215510 - Controlled Foreign Companies: before CTSA

Losses: pre-direction losses - management expenses

ICTA88/SCH24/PARA9

Claims under ICTA88/SCH24/PARA9 are competent only in respect of trading losses (or charges treated as losses – ICTA88/S393 (9)). No relief is due in respect of management expenses brought forward from accounting periods prior to the first period for which a direction falls to be given.