Corporation Tax Act 2009 section 463F

Profits available for relief under section 463E

Section 463F defines how to calculate the amount of loan relationship profits from earlier periods that are available to absorb a non-trading deficit carried back under section 463E.

• Only loan relationship profits from accounting periods ending within the 12 months immediately before the deficit period can be relieved
• Where an accounting period straddles the start of the 12-month window, only a time-apportioned share of its profits is available for carry-back relief
• Profits must be reduced by all prior reliefs — including trade loss relief, charitable donations relief, management expenses, and capital allowances — before carry-back relief is applied
• Carry-back relief under section 463E is effectively the last in the queue, only offsetting whatever loan relationship profits remain after all other claims and deductions have been given