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Draft FB 2014: Losses on a change of control

Sara Luder reviews the proposed changes that will ease the rules restricting the availability of relief for corporation tax losses when companies change ownership

The recently announced proposed changes to the rules on carried forward losses on a change of ownership are welcome but many pitfalls remain for the unwary.

Summary of the current rules

CTA 2010 Part 14 restricts the availability of relief for various corporation tax losses when companies change ownership.

Relief is restricted for trading losses in two situations: first when in any period of three years there is both a change in company ownership and a major change in the nature or conduct of a trade carried on by that company; and second where there is a change in company ownership which occurs at any...

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