CTA 2010 Part 22 Chapter 2/ Ss 954 – 957 (formerly ICTA88/S343ZA)

Chapter 2 of Part 22 of CTA 2010 comprises anti-avoidance sections that prevents the sale of unused capital allowances.

Background

A company that makes a loss in its trade may decide not to claim all or part of the capital allowances to which it is entitled. This is particularly the case when all that it would do is increase the loss for which it has no immediate use. If this happens for a number of years the pool of qualifying expenditure may be much higher than the value of the plant in it.

The company's owner may decide to sell it to a person who thinks that they will be able to turn it around and run it at a profit.

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