Finance Act 2015 introduces a new targeted anti-avoidance rule which counteracts arrangements under which certain carried forward losses are used to generate other losses or deductions which, for corporation tax purposes, can be used more flexibly. Where a company enters into arrangements meeting the conditions it will be unable to use these brought forward reliefs against profits created by the arrangements in the relevant company. The provisions mark a significant change of approach in relation to arrangements that have previously been seen as relatively benign.
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