'An avoidance scheme has been notified to HM Revenue and Customs (HMRC) that exploits the fact that corporation tax (CT) rules provide that losses arising in a trade in the 12 months prior to its cessation may be carried back and set off against profits made in the previous three years (“terminal loss relief”).
'The scheme works by artificially engineering a deemed cessation of trading. The deemed cessation of trading means that the company gains access to relief for the losses much earlier than Parliament intended and undermines Clause 23...
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'An avoidance scheme has been notified to HM Revenue and Customs (HMRC) that exploits the fact that corporation tax (CT) rules provide that losses arising in a trade in the 12 months prior to its cessation may be carried back and set off against profits made in the previous three years (“terminal loss relief”).
'The scheme works by artificially engineering a deemed cessation of trading. The deemed cessation of trading means that the company gains access to relief for the losses much earlier than Parliament intended and undermines Clause 23...
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If you do not subscribe but are a registered user, please enter your details in the following boxes: