Corporation Tax Act 2009 section 63

Bringing into account losses on overseas sovereign debt etc.

Section 63 preserves the ability of companies to bring into account previously restricted losses on overseas sovereign debt following the transition to the Corporation Tax Act 2009.

• Applies where a company ceased to be party to a loan relationship before the Finance Act 2005 repealed the overseas sovereign debt loss restriction rules
• Covers situations where part of a loss on overseas sovereign debt could not originally be brought into account for tax purposes due to the old restriction in Finance Act 1996
• Ensures that any debit which was available to be carried forward under the transitional rules in Finance Act 2005 remains available under the new Corporation Tax Act 2009 framework
• The loss may be brought into account in a subsequent period of account for the purposes of Part 5 of the Corporation Tax Act 2009, which now governs loan relationships