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The company reported a profit of about £142 000 in 2007. The next year it made a loss of £444 747 which it carried back against the 2007 profit reducing it to nil. The balance of the loss was carried forward. After an enquiry into the 2007 return HMRC increased the profits for that year to about £682 000. The company argued that the 2008 loss could be used against the revised 2007 profits. HMRC disagreed. The First-tier Tribunal and Upper Tribunal rejected the company’s appeal on the basis that the claim to carry back further losses was made after 30 April 2009 which was the deadline for amending the 2007 return.
The company appealed to the Court of Appeal.
TA 1988 s 393A (now CTA 2010 s 37) states that a carry back claim is made for all of the available losses. However it...
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