Streaming of losses – bad news
The Upper Tribunal has reversed the First Tier Tribunal decision (Leekes Limited) and consequently the position on the use of corporation tax trade losses of an acquired business is back to HMRC’s previous practice. When an acquired business is merged into an existing business, it will again be necessary to stream the profits of the merged entity so that brought forward trade losses of the acquired business can only be offset against future profits of that element of the new enlarged business.
Date: 5th August, 2016
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