Corporation Tax Act 2010 section 672

Overview of Part

Section 672 provides an overview of Part 14, which deals with the various restrictions on tax relief and recovery of unpaid corporation tax that can arise when there is a change in the ownership of a company.

• Trading loss relief may be restricted on a change of company ownership, a change in activities, or the transfer of an asset or trade, and group relief for carried-forward losses may also be limited.
• Relief may be restricted for companies with investment business, for property losses in companies without investment business, and for certain non-trading deficits and losses in shell companies, all triggered by a change of ownership.
• Unpaid corporation tax may be recovered from a linked person following a change in company ownership, and separately from non-UK resident companies under Part 22.
• Key definitions — including "change in the ownership of a company", "company with investment business", "shell company", and "linked person" — are set out in later chapters and sections of the Part.