Corporation Tax Act 2010 section 705E

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

Section 705E restricts the relief available for non-trading losses on intangible fixed assets when there has been a change in company ownership.

• Non-trading losses on intangible fixed assets must be apportioned separately to each notional accounting period created by the change in ownership
• Relief against total profits can only be claimed within each notional accounting period considered individually
• Non-trading losses arising before the change in ownership cannot be carried forward to any accounting period ending after the change
• Pre-change losses cannot be treated as if they were non-trading losses on intangible fixed assets of a post-change period