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HMRC is consulting on extending the 2017 corporation tax loss relief changes to transfers of business by mutual societies. The draft Mutual Societies (Transfers of Business) (Tax) (Amendment) Regulations 2024 are expected to apply retrospectively to transfers of business by building societies occurring from 1 January 2023.
In 2017, corporation tax loss reform introduced major changes to the use of losses. The amendments proposed in these draft regulations would update the current rules for building societies to reflect changes made as part of that loss reform in connection with transfers of trade and the use of losses. This includes greater flexibility for the offset of post-1 April 2017 trade losses, subject to some restrictions in the first five years after the transfer of business.
The comments on the draft regulations should be emailed to: financialservicesbai@hmrc.gov.uk by 28 February 2024.
