Draft legislation: Corporation Tax - bank loss relief restriction
This draft legislation is about restricting the proportion of banks� annual taxable profit that can be offset by carried forward losses to 50%.
Documents
Details
»Ê¹ÚÌåÓýapp measure will restrict the proportion of banksâ€� annual taxable profit that can be offset by carried forward losses to 50%.
»Ê¹ÚÌåÓýapp restriction will apply to carried forward:
- trading losses
- non-trading loan relationship deficits
- management expenses
»Ê¹ÚÌåÓýapp restriction will take effect from 1 April 2015 and will only apply to reliefs accruing prior to this date. »Ê¹ÚÌåÓýapp targeted anti-avoidance rule which forms part of the measure will apply to arrangements entered into on or after 3 December 2014.
A Tax Information and Impact Note for this measure has been published at Corporation Tax: bank loss relief restriction.
A technical note providing detail of how the proposed legislation will operate has been published at Restriction on brought forward reliefs in the UK banking sector - technical note.