Corporation Tax Act 2009 section 463D

Claim to set off deficit against profits for the deficit period

Section 463D sets out how a non-trading loan relationship deficit is relieved against a company's profits for the same accounting period in which the deficit arose.

• A company may claim to set off all or part of its non-trading loan relationship deficit against specified profits of the same accounting period
• The claim must identify both the amount of the deficit and the specific profits against which relief is sought, and those profits are reduced accordingly
• This relief takes priority over trade loss relief or UK property business loss relief for the same period, and over any carry-back of a non-trading deficit from a later period
• Relief cannot be given against ring fence profits from oil and gas activities or oil contractor activities