CTM06775 - Corporation Tax: loss buying: major change in the business of a transferred company: priority of provisions

CTA10/S676AB

The provisions of CTA10/PART14/CH2A do not apply where CTA10/PART14/CH2 or CH3 can be used instead.

This is achieved through priority rules, which operate where a loss or other amount meets the conditions of CTA10/PART14/CH2A but could also be restricted under any of the following provisions:

· Disallowance of trading losses (CTA10/PART14/CH2/S674),

· Restrictions on relief for companies with investment business (CTA10/PART14/CH3/S679-683).

In these circumstances, the provision in Chapter 2A that would otherwise restrict the loss does not apply. The available provision of Chapter 2 or Chapter 3 is used instead.