Jenny Doak senior associate at Freshfields Bruckhaus Deringer LLP considers the provisions in Finance Act 2009 Sch 12 which extend the ability of groups to reallocate capital losses and gains
The ability of corporate groups to use capital losses has been brought increasingly into focus by the recent economic downturn. Until this year's Finance Act TCGA 1992 s 171A (referred to in this article as 'old s 171A') provided some flexibility for groups to utilise capital losses of one company against gains made by other companies in the group but this was limited in some situations. The 'support for business' provisions in this year's Finance Act includes new ss 171A to s 171C which apply to gains or losses accruing on or after 21 July 2009 and...
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Jenny Doak senior associate at Freshfields Bruckhaus Deringer LLP considers the provisions in Finance Act 2009 Sch 12 which extend the ability of groups to reallocate capital losses and gains
The ability of corporate groups to use capital losses has been brought increasingly into focus by the recent economic downturn. Until this year's Finance Act TCGA 1992 s 171A (referred to in this article as 'old s 171A') provided some flexibility for groups to utilise capital losses of one company against gains made by other companies in the group but this was limited in some situations. The 'support for business' provisions in this year's Finance Act includes new ss 171A to s 171C which apply to gains or losses accruing on or after 21 July 2009 and...
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