Corporation Tax Act 2009 section 463G

Carry forward of unrelieved deficit against total profits

Section 463G explains how a company can carry forward any non-trading loan relationship deficit that has not been relieved in the current or earlier periods, and set it against total profits of the next accounting period.

• Any deficit amount not already relieved against current or earlier period profits, and not surrendered as group relief, is carried forward to the next accounting period
• The company may claim to set off all or part of this carried-forward deficit against its total profits for that next period, but not against ring fence profits from oil activities
• Special rules apply to Solvency 2 insurance companies where the deficit is partly a shock loss — only the non-shock-loss portion (the eligible amount) may be carried forward under this section
• The claim must be made within two years of the end of the accounting period to which the deficit is carried forward, unless HMRC allows a longer period