Section 676AH — Corporation Tax Act 2010: Restriction on the carry forward of post-1 April 2017 non-trading deficit from loan relationships

Restriction on the carry forward of post-1 April 2017 non-trading deficit from loan relationships 676AH 1 This section has effect for the purpose of restricting the carry forward under Chapter 16A of Part 5 of CTA 2009 (non-trading deficits: post 1 April 2017 deficits) of a pre-acquisition non-trading deficit from the transferred company's loan relationships.

2 For the purposes of this section an amount is a “pre-acquisition” non-trading deficit from a company's loan relationships if it is a non-trading deficit from the company's loan relationships for an accounting period beginning before the change in ownership.

3 Subsection (4) applies if, in the case of a pre-acquisition non-trading deficit from the transferred company's loan relationships, the non-trading deficit in column 1 of row 4 of the table in section 685(2) is apportioned in accordance with section 685(2) to the first notional accounting period.

4 None of that deficit may, by virtue of section 463G (carry forward of unrelieved deficit), be set off against affected profits of—

a the accounting period beginning immediately after the change in ownership, or b any subsequent accounting period.