Relief is restricted where a loss is sustained in a trade, profession or vocation carried on wholly outside the UK (ITA 2007, s. 95). Restrictions apply to:

sideways relief (see ¶290-740 and ¶290-755);

trade income relief (encompassing both carry-forward trade loss relief (see ¶290-830) and terminal trade loss relief (see ¶290-845); and

relief under TCGA 1992, s. 261B (use of trading loss as a CGT loss: see ¶290-740).

More specifically:

sideways relief for the loss is available only against the person’s ‘qualifying foreign income’;

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