A number of restrictions apply in respect of company losses:

relief for claims made under CTA 2010, s. 37 (sideways and carry-back relief for trade losses) may be restricted where there has been a qualifying change and a main purpose of that change was to give rise to a claim, or increased claim, for relief (the ‘transfer of deductions’ anti-avoidance rules) (CTA 2010, Pt. 14A);

trade loss relief (under CTA 2010, s. 37, 42 and 45) may be restricted where the ownership of a company has changed in proximity to a major change in the nature or conduct of the business (CTA 2010, Pt. 14);

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