Corporation Tax Act 2010 section 960

Restrictions on use of reliefs

Section 960 restricts how a partner company can use trading losses and other reliefs when arrangements to transfer relief within a partnership (as defined in section 959) are in place.

• A partner company's share of the firm's trading loss in a relevant accounting period can only be set against its own share of profits from that same partnership trade — not against the company's total profits or profits from other sources.
• Qualifying charitable donations made by the firm during a relevant accounting period are treated as a loss of that period for these purposes, meaning they too can only be relieved against the partner company's share of the firm's trading profits.
• Losses from other trades, or any other amounts that might otherwise qualify for corporation tax relief, cannot be deducted from the partner company's share of the firm's profits in a relevant accounting period.
• A "relevant accounting period" is any accounting period of the firm during which arrangements falling within section 959 exist or to which such arrangements apply.