Jenny Doak examines the two sets of provisions in FA 2013 intended to prevent corporate groups from accessing ‘unrealised’ losses from unrelated parties
Finance Act 2013 introduces ‘targeted loss buying’ rules intended to counter companies accessing ‘unrealised’ corporation tax losses from unconnected parties. As well as catching tax-motivated planning it is likely that the rules will have a wider impact potentially affecting M&A and other commercially driven transactions particularly in capital-intensive sectors.
The new rules are in two parts:
