Legislation in FA 2015 will restrict to 50% the proportion of annual taxable profit that banks can offset by certain carried-forward reliefs from 1 April 2015.
The restriction will apply to carried forward trading losses, non-trading loan relationship deficits, and management expenses accruing up to 1 April 2015. Two targeted anti-avoidance rules will apply to arrangements entered into on or after 3 December 2014.
HMRC updated their technical note on 26 March 2015 to include: new chapter 8 on the allowance for building societies and their groups; a new motive test for the TAARs now in chapter 9; and availability of double tax relief (new paragraph 47).
Also, as announced in Budget 2015, the government is consulting until 29 May 2015 on changes to make banks’ future compensation payments to customers non-deductible for corporation tax purposes. See the condoc.
Legislation in FA 2015 will restrict to 50% the proportion of annual taxable profit that banks can offset by certain carried-forward reliefs from 1 April 2015.
The restriction will apply to carried forward trading losses, non-trading loan relationship deficits, and management expenses accruing up to 1 April 2015. Two targeted anti-avoidance rules will apply to arrangements entered into on or after 3 December 2014.
HMRC updated their technical note on 26 March 2015 to include: new chapter 8 on the allowance for building societies and their groups; a new motive test for the TAARs now in chapter 9; and availability of double tax relief (new paragraph 47).
Also, as announced in Budget 2015, the government is consulting until 29 May 2015 on changes to make banks’ future compensation payments to customers non-deductible for corporation tax purposes. See the condoc.
