Parliament has identified an abuse of loss relief rules where, in their view, some corporate entities were using contrived avoidance arrangements to “refresh” brought forward losses and convert them into losses which could accelerate the tax relief available by giving in-year deductions.
Measures will be introduced which will cover corporation tax trading losses, non-trading loan relationship deficits and management expenses to ensure that where the conditions of the new rules apply, it will not be possible to use these losses to obtain tax relief.
This measure will have immediate effect.