LAM15060 - Excess expenses, losses and deficits:  Set-off of trade losses that are not long-term business losses

Losses from any business that is not long term i.e. short-term (general insurance) are treated as ‘normal’ trade losses. See CTM04000+ and CTM05000+.

In summary:

• losses can be set against the shareholders’ share of total profits (LAM15010) of the period;
• losses can be surrendered as group relief of the period;
• any remaining losses after set-off in the period of loss can be set against shareholders’ share of total profits of the previous 12 months;
• carried forward losses incurred before 1 April 2017 can only be set against profits of the same trade;
• carried forward losses incurred on or after 1 April 2017 can be:
  • set against the shareholders share of total profits (CTA10/S45A)
  • set against non-BLAGAB trade profit (CTA10/S45B)
  • surrendered as group relief

Set-off of carried forward trade losses is subject to the loss restriction rules (LAM15200).