Corporation Tax Act 2010 section 104

Meaning of "non-trading loss on intangible fixed assets"

Section 104 defines what counts as a "non-trading loss on intangible fixed assets" for the purposes of group relief surrenders, and excludes losses carried forward from earlier periods.

  • A non-trading loss on intangible fixed assets is defined by reference to the rules in Part 8 of the Corporation Tax Act 2009.
  • This type of loss is one of the amounts that a company may surrender as group relief under section 99(1)(g).
  • Losses carried forward from an earlier period and treated as non-trading losses on intangible fixed assets for the current surrender period are excluded from the definition.
  • Only losses arising in the surrender period itself are eligible — not amounts brought forward under section 753(3) of CTA 2009.

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