Corporation Tax Act 2010 section 684

Disallowance of overseas property business losses

Section 684 restricts the ability of a company to use losses from an overseas property business to reduce future profits when there has been a change in the company's ownership.

• This section applies where a company has made a loss in an overseas property business before a change in ownership takes place.
• The restriction targets the relief normally available under section 66, which allows overseas property business losses to be carried forward against future profits of the same business.
• Losses arising in accounting periods that began before the change in ownership cannot be set against profits of accounting periods that end after the change in ownership.
• The effect is to prevent new owners from benefiting from overseas property business losses that were generated under the previous ownership.