Corporation Tax Act 2009 section 463I

Re-application of section 463G if any deficit remains after previous application

Section 463I provides a mechanism for continuing to carry forward any non-trading loan relationship deficit that remains unused after a previous carry-forward period, allowing the company to claim relief against total profits in successive later periods.

• Where a deficit has been carried forward to a later accounting period but not fully used — either by set-off against total profits or by surrender as group relief for carried-forward losses — the remaining balance can be carried forward again to the next period.
• The carry-forward mechanism from section 463G reapplies to the unused portion as though the later period were the original deficit period, enabling a fresh claim for relief against total profits in the following accounting period.
• This continued carry-forward is only available if the company has not ceased to be a company with investment business during the later period and, where it was such a company immediately before the later period began, its investment business has not become small or negligible during that period.
• The carry-forward is also blocked if the first accounting period after the later period is an excluded accounting period of a general insurance company.