New HMRC draft guidance: Reform of Corporation Tax loss relief - Commencement and apportionment

Released 07 December 2017

HMRC are seeking comments on draft guidance on the corporation tax loss relief legislation (commencement and apportionment provisions) included in F(No.2)A 2017.

Reform of Corporation Tax loss relief: Commencement and apportionment has been published to explain the application of the commencement provisions included in the legislation for reform of corporation tax loss relief. The legislation is included in F(No.2)A 2017, s. 18 and 19 and Sch. 4. This guidance includes worked examples showing how the commencement provisions at Sch. 4, Pt. 12 may be applied. This follows a first tranche of guidance Reform to Corporation Tax loss relief: draft guidance, published on 31 July 2017 and a second tranche of guidance Reform of Corporation Tax loss relief: second tranche draft guidance, published on 6 November 2017. Comments should be emailed to The deadline for comments is 9 February 2018.

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