Corporation Tax Act 2010 section 676AF

Restriction on use of carried-forward post-1 April 2017 trade losses

Section 676AF restricts a company from using carried-forward trade losses arising on or after 1 April 2017 against its total profits after a change in ownership, where those profits are classed as "affected profits".

• Where a company changes ownership, trade losses made before the change cannot be set against "affected profits" of any accounting period ending after the change
• The restriction covers four types of carried-forward loss relief: general post-1 April 2017 trade loss carry-forward, terminal loss relief, excess carried-forward non-decommissioning losses of ring fence trades, and excess carried-forward BLAGAB trade losses
• The same restriction applies to losses originally made by a predecessor company whose trade was transferred to the company that changed ownership
• For these purposes, an accounting period is treated as ending on the date of the change in ownership, so losses are blocked from the point of ownership change onwards