Application of the corporate capital loss restrictions

Finance Bill 2020 Sch 3 contains the draft legislation (tinyurl.com/s79cewo) for the corporate capital loss restriction (CCLR). This should not come as a shock to most given that the government’s intention to introduce these rules was announced back at Budget 2018. However for those who may have forgotten amid all that is going on in the world this article provides a summary of the key changes and some practical implications.

The 2017 corporate loss reforms introduced by F(No 2)A 2017 Sch 4 amending CTA 2010 touted the joys of a new flexible corporate loss regime in which income losses arising in accounting periods ending on or after 1 April 2017 could be carried forward and offset against most profits of a company including gains. More importantly these losses could also...