Corporation Tax Act 2010 section 944D

Modified application of section 303B

Section 944D ensures that when a ring-fence trade is transferred, any unrelieved non-decommissioning losses from the predecessor company's final trading period can be carried forward and used by the successor company under the rules in section 303B.

• Applies where a ring-fence trade is transferred and the predecessor made a non-decommissioning loss in its final accounting period, which must begin on or after 1 April 2017
• Any portion of that loss not relieved under sections 37, 42 or Part 5 is treated as carried forward to the successor company
• The carry-forward rules in section 303B(2) to (5) are re-read so that references to the company, the trade and the relevant periods all point to the successor and the transferred trade
• A "non-decommissioning loss" and "ring-fence trade" take their meanings from sections 303A and 277 respectively