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HMRC’s agreement to a new interpretation for restricted loss relief.
KEY POINTS
- Restricted loss relief applies only to those reliefs that are not already subject to restrictions.
- How do brought-forward losses interact with claims to sideways relief?
- There is an apparent difference between legislation and HMRC guidance.
- Advisers should be aware that tax software may not give the expected result.
- HMRC agree that there needs to be clarification in the Helpsheet 204 worksheet.
Readers will be aware that from 6 April 2013 previously uncapped income tax reliefs have been restricted. This restriction was innocuously entitled “Limit on Step 2 deductions” and is found in ITA 2007 s 24A. HMRC refer to it as a “limit on income tax reliefs” but for many tax practitioners a “restriction on sideways loss relief”...
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