Article 5 Corporation Tax: losses
For the purposes of computing the profits of a property business under Part 4 of the Corporation Tax Act 2009f1 (property income), where as a result of a relevant transfer part of a property business (“the transferred part”) ceases to be carried on by BRB Residuary and is begun to be carried on by LCR—
any unrelieved loss relating to the transferred part of BRB Residuary’s property business is treated as a loss (“the transferred loss”) made by LCR in the first accounting period in which it carries on that business, and
the transferred loss is not a “UK property loss” for the purposes of Part 5 of the Corporation Tax Act 2010f2 (group relief).
For the purposes of paragraph (1)—
an unrelieved loss is the amount of any loss which—
cannot be deducted from the total profits of BRB Residuary for the last accounting period in which it carries on the transferred part of the business, and
would be available for carry forward to the next accounting period of BRBR under section 62 of the Corporation Tax Act 2010 if BRB Residuary continued to carry on the business, and
the proportion of any loss of BRB Residuary’s property business which relates to the transferred part of the property business is to be determined on a just and reasonable basis.