HMRC is consulting on draft regulations which, broadly, will apply the 2017 corporation tax loss relief changes to transfers of business by mutual societies. The draft Mutual Societies (Transfers of Business) (Tax) (Amendment) Regulations 2024 are expected to apply retrospectively to transfers of business by building societies occurring from 1 January 2023.
Regulation 4 of the Mutual Societies (Transfers of Business) (Tax) Regulations, SI 2009/2971, sets out the rules for the use of trade losses on certain transfers of business by building societies. The starting point is that the main corporation tax rules apply, but are subject to various modifications which are specific to building societies. The draft regulations will replace those modifications, the aim being both to introduce greater flexibility for the offset of post-1 April 2017 trade losses and to restrict the use of carried-forward trade losses for five years following a relevant transfer. The consultation on the draft regulations closes on 28 February 2024.
HMRC is consulting on draft regulations which, broadly, will apply the 2017 corporation tax loss relief changes to transfers of business by mutual societies. The draft Mutual Societies (Transfers of Business) (Tax) (Amendment) Regulations 2024 are expected to apply retrospectively to transfers of business by building societies occurring from 1 January 2023.
Regulation 4 of the Mutual Societies (Transfers of Business) (Tax) Regulations, SI 2009/2971, sets out the rules for the use of trade losses on certain transfers of business by building societies. The starting point is that the main corporation tax rules apply, but are subject to various modifications which are specific to building societies. The draft regulations will replace those modifications, the aim being both to introduce greater flexibility for the offset of post-1 April 2017 trade losses and to restrict the use of carried-forward trade losses for five years following a relevant transfer. The consultation on the draft regulations closes on 28 February 2024.
