For the purposes of the transfer pricing rules, the meaning of ‘losses’ is extended to include the following amounts:

pre-trading expenses for which relief is given by ITTOIA 2005, s. 57 (see ¶208-300) or CTA 2009, s. 61 (see ¶707-410);

certain interest carried forward under ITA 2007, s. 88 (see ¶261-750);

pre 1-April 2017, non-trading deficits on loan relationships for which relief is given by CTA 2009, Pt. 5, Ch. 16 (see ¶717-150);

post 1-April 2017, non-trading deficits on loan relationships for which relief is given by CTA 2009, Pt. 5, Ch. 16A (see ¶717-150);

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