Corporation Tax Act 2010 section 269ZC

Restriction on deductions from non-trading profits

Section 269ZC limits the amount of carried-forward non-trading loan relationship deficits that a company can deduct against its non-trading profits in any accounting period, as part of the corporate loss restriction rules.

• Carried-forward non-trading loan relationship deficits (specifically pre-1 April 2017 deficits and charity deficits) set against non-trading profits are capped at the "relevant maximum" less any deductions for capital losses from earlier periods
• The relevant maximum is 50% of the company's total relevant non-trading profits for the period, plus the company's total non-trading profits deductions allowance
• The total non-trading profits deductions allowance is split between a non-trading income profits deductions allowance and a chargeable gains deductions allowance, both drawn from the company's overall deductions allowance as specified in its tax return
• The restriction does not apply where the company's non-trading income profits and chargeable gains (before these carried-forward deductions) are nil or negative