Corporation Tax Act 2010 section 700

Disallowance of UK property business losses

Section 700 restricts the relief available for UK property business losses incurred before a change in company ownership, ensuring that such losses cannot be used to shelter certain gains arising after the ownership change.

• This section limits relief under sections 62 and 63 for UK property business losses made before a change in company ownership.
• The restriction only applies where chargeable gains or non-trading chargeable realisation gains are included in the company's total profits for the accounting period in which the relevant gain accrues, in accordance with the relevant provisions and section 702.
• Relief under section 62(3) can only be claimed against each notional accounting period considered on its own, not across periods collectively.
• Losses from an accounting period beginning before the ownership change cannot be deducted from that portion of post-change accounting period profits that represents the relevant gain.