Corporation Tax Act 2010 section 673

Introduction to Chapter

Section 673 introduces the rules that restrict the use of a company's tax losses when there has been a change in the company's ownership combined with either a major change in the nature of its trade or a period where the trade had become dormant or near-dormant.

• The chapter applies when a company undergoes a change of ownership and one of two conditions is met
• Condition A is met where, within a period of up to five years that begins no more than three years before the ownership change, there is a major change in the nature or conduct of the company's trade
• Condition B is met where the ownership change occurs after the company's trade activities have become small or negligible but before any significant revival of that trade
• A major change in the nature or conduct of a trade includes changes in the type of property dealt in, services or facilities provided, or changes in customers, outlets or markets — even if the change resulted from a gradual process that began before the five-year window