The Mutual Societies (Transfers of Business) (Tax) (Amendment) Regulations, SI 2024/555, amend reg 4 of the Mutual Societies (Transfers of Business) (Tax) Regulations, SI 2009/2971 to reflect the current provisions in the CTA 2010 in relation to the use of carried-forward trade losses in the event of transfers of business by building societies.
The amended regulations will apply the current legislation on transfer of losses to relevant transfers by building societies from 1 January 2023. This includes restrictions on the use of pre-April 2017 losses in the first five years after a transfer involving a change of ownership.
The changes aim to ensure consistency of treatment between building societies and companies undertaking similar business transfers. HMRC have also published a Tax Information and Impact Note explaining the background to the changes.
The Mutual Societies (Transfers of Business) (Tax) (Amendment) Regulations, SI 2024/555, amend reg 4 of the Mutual Societies (Transfers of Business) (Tax) Regulations, SI 2009/2971 to reflect the current provisions in the CTA 2010 in relation to the use of carried-forward trade losses in the event of transfers of business by building societies.
The amended regulations will apply the current legislation on transfer of losses to relevant transfers by building societies from 1 January 2023. This includes restrictions on the use of pre-April 2017 losses in the first five years after a transfer involving a change of ownership.
The changes aim to ensure consistency of treatment between building societies and companies undertaking similar business transfers. HMRC have also published a Tax Information and Impact Note explaining the background to the changes.
