The amount of loss available to a company for surrender was restricted to trading losses or capital allowances, and was not to include allowable losses. The sums to be surrendered were those which might appear in a calculation of profits for the period. Therefore allowable losses from previous years activities were not to be brought forward for deduction against chargeable gains.
Rattee J
Times 12-Jun-2001, [2002] STC 430
Income and Corporation Taxes Act 1988 403 (7)
England and Wales
Citing:
Appealed to – Taylor (Inspector of Taxes) v MEPC Holdings Ltd CA 20-Jun-2002
The taxpayer sought to include in the amounts to be set off by surrender against the group’s liability for corporation tax, chargeable gains in respect of allowable losses of a preceding accounting period. They appealed a decision against them at . .
Cited by:
Appeal from – Taylor (Inspector of Taxes) v MEPC Holdings Ltd CA 20-Jun-2002
The taxpayer sought to include in the amounts to be set off by surrender against the group’s liability for corporation tax, chargeable gains in respect of allowable losses of a preceding accounting period. They appealed a decision against them at . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax
Updated: 09 January 2022; Ref: scu.89732
