Mark Boyle and Chris Lord (EY) analyse whether Leekes may make it possible in certain circumstances to claim loss relief for historic losses of the transferred trade without streaming.
The First-tier Tribunal decision in Leekes Ltd v HMRC [2015] UK FTT 93 is perhaps the first case to consider directly the use of carried forward trading losses following a transfer of a trade commonly referred to as the ‘loss streaming’ provisions. This is despite the fact that these provisions have been on the books in broadly their current form since at least 1965.
Leekes Ltd (‘Leekes’) a UK company...
