{
  "url": "https://openlegislation.uk/corporation-tax-act-2010/section-269CB",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2010/section-269CB.json",
  "legislation": "ukpga/2010/4",
  "legislation_title": "Corporation Tax Act 2010",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2010",
  "path": "section/269CB",
  "kind": "section",
  "number": "269CB",
  "heading": "Restriction on deductions for non-trading deficits from loan relationships",
  "text": "(1) This section has effect for determining the taxable total profits of a banking company for an accounting period.\n(2) Any deduction made by the company for the accounting period in respect of a pre-2015 carried-forward non-trading deficit may not exceed 25% of the company's total relevant non-trading profits for the accounting period.\nSection 269ZF contains provision for calculating a company's total relevant non-trading profits for an accounting period (see subsection (2B) of that section).\n(3) But subsection (2) does not apply in relation to a banking company for an accounting period where, in determining the company's total relevant non-trading profits for the period, the amount given by step 1 in section 269ZF(3) is not greater than nil.\n(4) In this Chapter “pre-2015 carried-forward non-trading deficit”, in relation to a company and an accounting period (“the current accounting period”), means a non-trading deficit—\n(a) which the company had from its loan relationships under section 301(6) of CTA 2009 for an accounting period ending before 1 April 2015, and\n(b) which is carried forward under section 457 of that Act (carry forward of deficits to accounting periods after deficit period) to be set off against non-trading profits of the current accounting period.\n(5) In subsection (4) “non-trading profits” has the same meaning as in section 457 of CTA 2009.\n(6) See also sections 269CE to 269CH (losses to which restrictions do not apply).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 7A inserted (with effect in accordance with Sch. 2 para. 7-9 of the amending Act) by Finance Act 2015 (c. 11), Sch. 2 para. 1"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Word in s. 269CB(2) substituted (with effect in accordance with s. 57(5) of the amending Act) by Finance Act 2016 (c. 24), s. 57(3)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 269CB(2) substituted (with effect in relation to accounting periods beginning on or after 1.4.2020 of the amending Act) by Finance Act 2020 (c. 14), Sch. 4 paras. 37(2)(a), 42 (with Sch. 4 paras. 43-46)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "Word in s. 269CB(2) substituted (with effect in accordance with Sch. 4 para. 190 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 4 para. 19(2)(a)"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Words in s. 269CB(2) substituted (with effect in relation to accounting periods beginning on or after 1.4.2020 of the amending Act) by Finance Act 2020 (c. 14), Sch. 4 paras. 37(2)(b), 42 (with Sch. 4 paras. 43-46)"
    },
    {
      "type": "F",
      "label": "F6",
      "text": "Words in s. 269CB(3) substituted (with effect in accordance with Sch. 4 para. 190 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 4 para. 19(3)"
    },
    {
      "type": "F",
      "label": "F7",
      "text": "Words in s. 269CB(3) substituted (with effect in relation to accounting periods beginning on or after 1.4.2020 of the amending Act) by Finance Act 2020 (c. 14), Sch. 4 paras. 37(3), 42 (with Sch. 4 paras. 43-46)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/4/section/269CB",
    "retrieved_at": "2026-10-29T09:10:29.433154+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}