Corporation Tax Act 2010 section 269CH

Losses covered by carried-forward loss allowance

Section 269CH allows building societies and certain banking companies within a building society group to designate carried-forward losses as "unrestricted", so that the banking surcharge restriction on the use of those losses does not apply.

  • Building societies receive an initial carried-forward loss allowance of £25,000,000, which they can use themselves or allocate to group companies
  • Losses designated as unrestricted are treated as falling outside the restriction rules, meaning they can be used in full against profits
  • The allowance is cumulative and not tied to any single accounting period — unused allowance carries forward until it is fully designated
  • Designations are made through the company's corporation tax return and can be included in an original return or added by amendment

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