Corporation Tax Act 2009 section 1105

Amount of trading loss which is "unrelieved"

Section 1105 defines what portion of a trading loss remains "unrelieved" by identifying all the other ways in which a company may already have obtained relief for that loss.

• A trading loss is "unrelieved" to the extent that it has not been reduced or used up through other available relief mechanisms.
• The section lists the various forms of relief that can reduce the amount of a trading loss, such as group relief, carry-back, or set-off against other profits.
• Only the portion of the loss that has not been dealt with through any of these other relief routes qualifies as "unrelieved" for the purposes of the overseas losses rules.
• This definition is important because it determines the amount of the loss that remains available under the specific provisions for relief of overseas losses of a UK company's foreign permanent establishments.