Corporation Tax Act 2009 section 463E

Claim to carry back deficit to earlier periods

Section 463E sets out the rules and limits that apply when a company claims to carry back a non-trading loan relationship deficit to set it off against profits of accounting periods earlier than the deficit period.

• A company may claim to carry back all or part of its non-trading loan relationship deficit to be set off against profits of earlier accounting periods
• The amount carried back cannot exceed the lower of the deficit remaining after any current-period set-off claim and the total profits available for relief in those earlier periods
• The profits available for relief are determined by the rules in section 463F
• Where carry-back covers more than one earlier accounting period, the deficit must be set against the most recent period first before any remainder is applied to still earlier periods