Corporation Tax Act 2010 section 269CE

Losses arising before company began banking activity

Section 269CE excludes from the banking company loss restriction any carried-forward reliefs that arose before the company began carrying on relevant regulated activity.

• Losses, deficits and management expenses arising before a company's first banking accounting period are excluded from the restriction on carried-forward deductions
• The first banking accounting period is the accounting period in which the company first begins to carry on a relevant regulated activity
• Where a company begins relevant regulated activity part-way through an accounting period, there is no need to apportion that period — the whole period counts as the first banking accounting period
• Relevant regulated activity includes activity of a type that would be regulated under the Financial Services and Markets Act 2000, even if the company carrying it on is not itself regulated under that Act