KEY POINTS
- Loss on loans to traders under TCGA 1992 s 253.
- The conditions for the relief to be given.
- Negligible value claims under TCGA 1992 s 24.
- Fletcher v HMRC and the implications of share reconstructions.
- Share loss relief under ITA 2007.
- Identifying the qualifying shares.
A recent Readers’ Forum query Road to redemption prompted me to think that it would be useful to summarise the potential reliefs available for losses incurred by an individual where he invests his money in a trade or company which subsequently either becomes irrecoverable or realises a loss on a (deemed) disposal.
This article focuses on three sets of such reliefs (apart from the normal capital gains tax loss relief) each of which...
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