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Corporate capital loss restriction: consultation

Tim Jarvis (Squire Patton Boggs) considers the proposals designed to align the rules on corporate capital losses with those on income losses.
 

Budget 2018 announced a consultation on the corporate capital loss restriction (CCLR). The consultation opened on 29 October 2018 and it is scheduled to close on 25 January 2019 (see bit.ly/2Ogq9b5). The consultation’s purpose is to assist in the design of legislation which will take effect from 1 April 2020.

Thumbnail sketch of the CCLR

The CCLR can be regarded as an addendum or a follow-on to the corporate income loss restriction (CILR) which was introduced with effect from 1 April 2017. To understand the CCLR it is first necessary to explain what the CILR did and did not do.

The CILR is a hybrid beast: it is simultaneously a liberalising and a restricting measure. The CILR is a liberalising measure because post-1 April...

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