Proposed Finance Bill changes will ease the rules restricting the availability of relief for corporation tax losses when companies change ownership. The insertion of a new group holding company will no longer be a change of ownership and the threshold for ‘a significant increase in a company’s capital’ is to be increased. These changes are not a complete solution and practical problems remain. An exception for bona fide commercial transactions would be welcome, although international trends would suggest that rules of this type are common, and the UK carry forward loss regime could be more restrictive.
