Taxation (International and Other Provisions) Act 2010 section 53

Earlier years' non-trading deficits on loan relationships

Section 53 deals with how non-trading deficits on loan relationships carried forward from earlier years are allocated when calculating the double taxation credit relief limit.

• When a non-trading deficit on loan relationships is carried forward from an earlier period, it must be allocated only against the company's non-trading profits for the current period.
• The company has flexibility to choose which non-trading profits to set the deficit against, and in whatever amounts it considers appropriate.
• This section harmonises the double taxation credit relief rules with the loan relationships regime, ensuring that carried-forward deficits are properly analysed for credit relief purposes.
• Non-trading profits has the same meaning as defined in section 457(5) of the Corporation Tax Act 2009.