‘Sideways relief’ (see ¶261-000) is in certain circumstances denied to an individual for losses derived from first-year allowances (ITA 2007, s. 76). The restriction also applies, in relation to expenditure incurred from 6 April 2008, to losses derived from annual investment allowances (FA 2008, Sch. 24, para. 21). These restrictions apply:

in certain cases involving partnerships with companies; and

in cases where there are artificial arrangements to reduce tax liabilities.

If relief has been given despite the restrictions of ITA 2007, s. 76 then the relief is withdrawn by the making of an assessment under ITA 2007, s. 79.

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