Corporation Tax Act 2010 section 269ZBA

Restriction on deductions from chargeable gains

Section 269ZBA limits how much of a company's brought-forward capital losses can be set against its chargeable gains in an accounting period when calculating taxable total profits.

• Capital losses carried forward from earlier periods cannot be deducted against current-period chargeable gains beyond a defined cap called the "relevant maximum".
• The relevant maximum is the sum of 50% of the company's relevant chargeable gains for the period, plus the company's chargeable gains deductions allowance for the period.
• The chargeable gains deductions allowance is the portion of the company's overall deductions allowance that it allocates to chargeable gains in its tax return; it shares that overall allowance with trading profits, non-trading income profits and, for insurers, BLAGAB deductions.
• The restriction does not apply at all for a period in which the company's qualifying chargeable gains (as determined at Step 1 in section 269ZF(3)) are nil or negative.

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