Corporation Tax Act 2010 section 993

Harbour reorganisation schemes: chargeable gains

Section 993 sets out the rules for how loss relief against chargeable gains works when a trade is transferred to a harbour authority under a harbour reorganisation scheme.

• When a trade is transferred to a harbour authority under a harbour reorganisation scheme, special rules apply to the treatment of chargeable gains and losses.
• The transferring body's allowable losses on chargeable gains arising from the trade can be carried over to the harbour authority receiving the trade.
• The harbour authority can use those transferred losses to offset against its own chargeable gains, as if the losses had originally been its own.
• This ensures continuity of loss relief so that genuine trading losses are not wasted simply because the trade has moved to a new entity under a statutory reorganisation.