Income Tax Act 2007 section 102

Overview of Chapter

Section 102 introduces the chapter that restricts trade loss relief available to individuals who carry on a trade as certain types of partner, and in certain other specific circumstances.

• Loss relief is restricted for individuals trading as a limited partner, a member of a limited liability partnership (LLP), or a non-active partner, with the cap generally linked to the individual's capital contribution to the firm
• Additional restrictions apply where the partnership trade involves the exploitation of films
• No relief is available where a loss has been disproportionately allocated to an individual partner instead of a non-individual partner (such as a company)
• Anti-avoidance provisions in Part 13 of the Act impose income tax charges to recover excess relief already given in partnership loss situations, including film-related and licence-related trading losses

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