Cap on relief (overview)

Capital loss restriction (from April 2020)

Accounting periods straddling 1 April 2020

Connected party ('clogged') losses

Extension to capital gains

Non-resident companies with UK property business

Pre-entry losses

Worked example

Capital losses carried forward

Deductions allowance (DA)


Chargeable gains DA


Company with capital gains only

Excessive claims


Group allowance allocation statement

Group DA

Insolvent companies (additional DA for)

Key points

Nominated company (group DA)

Non-trading IFA losses carried forward

Non-trading income profits DA

Onerous leases

Overview of restriction

Relevant deductions

Structure of

Total non-trading profits DA

Total profits exceed DA

Total profits less than DA

Trading profits DA

Future total profits (losses set against)


Introduction of limit

Key principles

Non-trading income profits only (restriction re)

Relevant deductions

Relevant maxima (calculation of)

Relevant profits (calculation of)

Scope of restriction

Specialist sectors

Streaming requirement

Trading profits only (restriction re)