Corporation Tax Act 2009 section 462

Claim to carry back deficit to earlier accounting periods

Section 462 sets out how a company can carry back a non-trading loan relationship deficit to set it against profits of earlier accounting periods.

• A company may claim to carry back all or part of its non-trading loan relationship deficit to earlier accounting periods, provided it has not already claimed that portion against current period profits.
• The amount that can be carried back is limited to the lower of the unclaimed deficit and the total profits available for relief in those earlier periods.
• Where there are profits in more than one earlier accounting period, the deficit must be set against the profits of the later period first before any remainder is applied to an earlier period.
• The relief works by treating the profits of the earlier periods as reduced by the amount of the deficit set against them.