CTA 2010, Part 14, Ch. 2C applies if on or after 1 April 2017 there is a change of ownership of a company.

(CTA 2010, s. 676CA)

Ch. 2C then provides for the exclusion of relief, or a restriction on relief, in a number of situations, below.

In these provisions, ‘the transferred company’ is the company subject to a change of ownership; a ‘co-transferred company’ is defined in s. 676CI(1),(2).

Restriction on surrender of carried-forward losses:

In the case of a claim for group relief for carried-forward losses (that would otherwise be eligible to be made):

(1)for an accounting period ending after the change in ownership, and

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