Corporation Tax Act 2010 section 681

Restriction on relief for non-trading loss on intangible fixed assets

Section 681 restricts the relief available for non-trading losses on intangible fixed assets when there has been a change in ownership of a company.

• Relief for non-trading losses on intangible fixed assets is restricted where there is a change in company ownership
• Any offset of losses against total profits in the accounting period spanning the ownership change must be considered separately for each notional accounting period (before and after the change)
• Non-trading losses on intangible fixed assets arising before the change in ownership cannot be carried forward to accounting periods ending after the change
• Such pre-change losses cannot be treated as if they were non-trading losses on intangible fixed assets of a later period