Corporation Tax Act 2009 section 1096

Treatment of deemed trading loss under section 1092

Section 1096 restricts how a deemed trading loss arising under section 1092 can be used and explains how any unused portion of that loss is carried forward.

• Where a deemed trading loss arises under section 1092, this section limits the ways in which that loss can be relieved.
• The loss cannot be used without restriction — specific constraints apply to prevent it being set against profits more broadly than intended.
• Any part of the deemed trading loss that remains unused after applying the available reliefs is carried forward and dealt with in accordance with the rules set out in this section.
• The effect of section 1096 mirrors that of section 1048, which imposes equivalent restrictions on deemed trading losses in a parallel context.