Section 269CB — Corporation Tax Act 2010: Restriction on deductions for non-trading deficits from loan relationships

Restriction on deductions for non-trading deficits from loan relationships 269CB 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 non-trading deficit may not exceed 25% of the company's total relevant non-trading profits for the accounting period. Section 269ZF contains provision for calculating a company's total relevant non-trading profits for an accounting period (see subsection (2B) 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 total relevant non-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 non-trading deficit ”, in relation to a company and an accounting period (“the current accounting period”), means a non-trading deficit—

a which the company had from its loan relationships under section 301(6) of CTA 2009 for an accounting period ending before 1 April 2015, and b which is carried forward under section 457 of that Act (carry forward of deficits to accounting periods after deficit period) to be set off against non-trading profits of the current accounting period.

5 In subsection (4) “ non-trading profits ” has the same meaning as in section 457 of CTA 2009.

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