LAM15070 - Excess expenses, losses and deficits: Set-off of BLAGAB capital losses: FA12/S75, TCGA92/S210A and TCGA92/S212
- BLAGAB capital losses (LAM03200) can be set against BLAGAB chargeable gains of the period (FA12/S75) (including deemed gains LAM03300);
- any BLAGAB capital loss carried forward must be set against BLAGAB chargeable gains of those subsequent periods (FA12/S75);
- the shareholders’ share of the net BLAGAB allowable loss can be set against non-BLAGAB gains (TCGA92/S210A) (LAM03420).
A net allowable loss arising from a deemed disposal under TCGA92/S212 (LAM03340) can be carried back (in full or in part) and set against net chargeable gains arising from the deemed disposal in the previous two accounting periods.
Any net allowable loss remaining is spread over 7 years. 1/7th of the net allowable loss is treated as an allowable loss of the accounting period with a further 1/7th (pro rata if the accounting period is shorter than twelve months) treated as an allowable loss at the end of each succeeding accounting period.