Corporate capital loss restriction: consultation on delivery

The ATT and CIOT have responded to a consultation on including carried forward capital losses in the corporate loss restriction

At Budget 2018 the Chancellor announced that the corporate income loss restriction (CILR) introduced in April 2017 would be extended to include carried forward capital losses from 1 April 2020. A consultation Corporate Capital Loss Restriction: Consultation on delivery was subsequently launched to consider how to implement this change, whether any specific exemptions were needed and if there were any potentially unintended consequences.

The ATT’s response to this consultation focuses primarily on the administrative impact of the proposals, in particular with respect to those smaller companies which are likely to suffer no financial restriction because of the availability of the £5m deductions allowance.