Section 269CA — Corporation Tax Act 2010: Restriction on deductions for trading losses

Restriction on deductions for trading losses 269CA 1 This section has effect for determining the taxable total profits of a banking company for an accounting period.

2 Any deduction made by the company for the accounting period in respect of a pre-2015 carried-forward trading loss may not exceed 25% of the company's relevant trading profits for the accounting period. Section 269ZF contains provision for calculating a company's relevant trading profits for an accounting period (see ... subsection (1) of that section).

3 But subsection (2) does not apply in relation to a banking company for an accounting period where, in determining the company's relevant trading profits for the period, the amount given by step 1 in section 269ZF(3) is not greater than nil .

4 In this Chapter “ pre-2015 carried-forward trading loss ”, in relation to a company and an accounting period (“the current accounting period”), means a loss which—

a was made in a trade of the company in an accounting period ending before 1 April 2015, and b is carried forward to the current accounting period under section 45 (carry forward of trade loss against subsequent trade profits).

5 See also sections 269CE to 269CH (losses to which restrictions do not apply).