Part 2 Restriction on Deductions in Respect of Carried-Forward Losses

Part 2 Restriction on Deductions in Respect of Carried-Forward Losses

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CTA 2010 is amended as follows.

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After section 269 insert—

“Part 7ZA
Restrictions on Obtaining Certain Deductions

Introduction

269ZA Overview of Part

This Part contains provision restricting the amount of certain deductions which a company may make in calculating its taxable total profits for an accounting period.

Restrictions on obtaining certain deductions

269ZB Restriction on deductions from trading profits

(1)     This section has effect for determining the taxable total profits of a company for an accounting period.

(2)     The sum of any deductions made by the company for the accounting period which fall within subsection (3) may not exceed the relevant maximum.

But this is subject to subsection (10).

(3)     The following deductions fall within this subsection—

(a)     any deductions under section 45(4)(b) or 45B;

(b)     any deduction under section 303B(4) or 303D(5), so far as it is a restricted deduction.

(4)     For the purposes of this section a deduction under section 303B(4) or 303D(5) is a “restricted deduction†so far as it would not be available but for section 304(5) (reduction of income derived from related activities).

(5)     In this section the “relevant maximum†means the

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