Income Tax Act 2007 section 103

Meaning of "sideways relief", "capital gains relief" and "firm"

Section 103 defines three key terms used throughout the chapter on restrictions on trade loss relief for certain partners: "sideways relief", "capital gains relief" and "firm".

• Sideways relief means either trade loss relief against general income (sections 64 to 70) or early trade losses relief available in the first four years of a trade (sections 72 to 74).
• Capital gains relief means converting a trade loss into an allowable capital loss under section 261B of the Taxation of Chargeable Gains Act 1992, and is treated as given when the loss is so converted.
• The term "firm" has the same meaning as in Part 9 of ITTOIA 2005, which contains the special rules for partnerships.
• These definitions apply throughout the chapter and are essential for understanding the restrictions that limit how certain partners can use their share of trading losses.