Income Tax Act 2007 Schedule 2 paragraph 24

Sideways relief: dealings in commodity futures

Schedule 2 paragraph 24 provides a transitional exemption from the restriction on sideways loss relief for commodity futures arrangements that pre-date 6 April 1976.

• Section 81 restricts sideways relief where a trade loss arises from arrangements involving dealings in commodity futures
• This restriction does not apply where the relevant arrangements were made wholly before 6 April 1976
• The exemption only applies if all of the arrangements were in place before that date — partial arrangements do not qualify
• This is a transitional provision preserving the treatment of pre-existing commodity futures arrangements