Corporation Tax Act 2009 section 391

Carry forward of surplus deficit to next accounting period

Section 391 deals with what happens to any remaining loan relationship deficit of an insurance company that has not been used up through set-off against the current period or carried back to an earlier period.

• Any deficit that has not been set off against income and gains of the deficit period must be carried forward
• Any deficit that has not been carried back against profits of an earlier period under a claim must also be carried forward
• The unused deficit is carried forward to the accounting period immediately following the deficit period
• The carried-forward deficit is treated as a deemed BLAGAB management expense in that next period