Corporation Tax Act 2010 section 269CA

Restriction on deductions for trading losses

Section 269CA restricts the amount of pre-April 2015 trading losses that banking companies can set against their current trading profits when calculating taxable total profits.

• Banking companies can only deduct pre-2015 carried-forward trading losses up to a maximum of 25% of their relevant trading profits for the accounting period
• The restriction does not apply where the banking company has no relevant trading profits (i.e. profits are nil or less)
• Pre-2015 carried-forward trading losses are defined as losses from a trade in accounting periods ending before 1 April 2015, carried forward under the normal trading loss carry-forward rules
• Certain exemptions from the restriction exist for specific categories of losses, set out in sections 269CE to 269CH