Corporation Tax Act 2010 section 676CH

Relevant pre-acquisition loss

Section 676CH defines what counts as a "relevant pre-acquisition loss" for the purposes of restricting group relief for carried-forward losses following a change in company ownership.

• A relevant pre-acquisition loss is any of seven specified types of loss or expense that originated in an accounting period beginning before a change of ownership and has been carried forward to the surrender period
• The seven categories cover non-trading loan relationship deficits, intangible fixed asset losses, management expenses of investment businesses, post-April 2017 trade losses, UK property business losses, ring fence trade non-decommissioning losses, and BLAGAB trade losses
• The common thread is that each loss must have arisen before the change of ownership and been carried forward into the period in which group relief surrender is being considered
• The "surrender period" takes its meaning from section 188BB(7) of CTA 2010, which defines it in the context of group relief for carried-forward losses