Corporation Tax Act 2009 section 1179BF

Carrying forward of production losses

Section 1179BF restricts how losses arising in the separate production trade during pre-completion periods can be used, and sets out the limited circumstances in which they may be carried forward or otherwise relieved.

• Losses made in the separate production trade during pre-completion periods cannot be used for any form of loss relief except as specifically permitted by this section.
• Such losses can be carried forward and set against future profits of the same separate production trade, and when they are, the corporate loss restriction (the cap on deductions from trading profits) does not apply to them.
• To the extent that a pre-completion loss could be carried forward to the completion period or a later accounting period, the company may instead choose to treat it as if it were a loss of that later period, making it available for sideways relief against total profits or for group relief.
• This alternative treatment is not available to the extent that the loss has been transferred to another qualifying production under the terminal loss transfer rules in section 1179BG.