Companies are charged to corporation tax on the sum of their income and chargeable gains (CTA 2009, s. 2(1) and (2)). However, losses from chargeable sources are not simply included in that process of aggregation so as to reduce chargeable profits. Each source of loss is subject to specific corporation tax provisions.

Of the rules for the various sources, those for relieving trading losses are the most elaborate. Very broadly, the reliefs potentially available for a trading loss include:

(1)sideways relief i.e. set-off against total profits (income and chargeable gains) of the accounting period in which the loss arose under CTA 2010, s. 37 (¶730-150);

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