Corporation Tax Act 2010 section 944C

Modified application of section 45F

Section 944C restricts the predecessor company from claiming terminal loss relief under section 45F for losses made in a transferred trade, and sets out how such losses may instead be treated as the successor's losses in certain circumstances.

• When a trade is transferred under the relevant Chapter, the predecessor company cannot claim terminal loss relief (section 45F) for losses arising in the transferred trade.
• An exception applies where the trade was transferred before 13 July 2017 and the loss was a pre-1 April 2017 trade loss carried forward under section 45 to the predecessor's final accounting period.
• If the predecessor's carried-forward losses reach the successor's final accounting period for the transferred trade but are not relieved there, the losses are treated as if the successor had made them.
• In that case, the losses are deemed to have arisen in the accounting period when the successor first began carrying on the transferred trade, enabling the successor to claim terminal loss relief instead.

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