Readers' forum: Going back

I have a question on the interaction of the income tax relief caps introduced in FA 2013 Sch 3 and share loss relief under ITA 2007 s 131.

Our client made a capital loss of £200 000 on a shareholding he held in an unquoted trading company (not enterprise investment scheme) which was liquidated in 2017-18 when he was a 40% taxpayer. Although he also made capital gains of £180 000 in 2017-18 because all the criteria under ITA 2007 s 131 are met I was proposing to offset £50 000 against his general income for 2017-18 which is fine. However I was wondering whether it would be feasible to offset a further £50 000 against 2016-17 (rather than against capital gains of the same year).

Any thoughts from Taxation readers would be greatly appreciated.

Query 19 281– Adviser.

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