Corporation Tax Act 2009 section 463C

Time limits for claims under section 463B(1)

Section 463C sets out the time limits for making claims to relieve a non-trading loan relationship deficit against profits of the current or earlier periods, and explains how multiple claims may be made in respect of different parts of the same deficit.

• A claim to relieve a non-trading deficit must be made within 2 years after the end of the deficit period, unless HMRC allows a longer period.
• HMRC has discretion to extend the 2-year time limit on a case-by-case basis.
• A company may make separate claims in respect of different parts of the same non-trading deficit for a given period.
• However, no claim may be made in respect of any part of a deficit that is already the subject of another claim — in other words, there must be no overlap or duplication between claims.