{
  "url": "https://openlegislation.uk/finance-act-2020/schedule-4/paragraph-18",
  "json_url": "https://openlegislation.uk/finance-act-2020/schedule-4/paragraph-18.json",
  "legislation": "ukpga/2020/14",
  "legislation_title": "Finance Act 2020",
  "legislation_url": "https://openlegislation.uk/finance-act-2020",
  "path": "schedule/4/paragraph/18",
  "kind": "paragraph",
  "number": "18",
  "heading": null,
  "text": "(1) Schedule 7A to TCGA 1992 (restriction on set-off of pre-entry losses) is amended in accordance with this paragraph.\n(2) In paragraph 6(1)(b), after “from that gain” insert “ (subject to sub-paragraphs (1A) to (1C)) ”.\n(3) In paragraph 6(1)(c), after “section 2A(1)” insert “ (subject to sub-paragraphs (1A) to (1C)) ”.\n(4) After sub-paragraph (1) insert—\n“(1A) Sub-paragraph (1B) applies, in respect of an accounting period, if the amount of chargeable gains accruing to the company in the period exceeds the total of—\n(a) the amount of pre-entry losses accruing to the company in the period that are deductible under sub-paragraph (1)(a), and\n(b) the amount of allowable losses, other than pre-entry losses, accruing to the company in the period.\n(1B) Where this sub-paragraph applies in respect of an accounting period—\n(a) the sum of any deductions under sub-paragraph (1)(b) may not exceed the total of—\n(i) the amount of pre-entry losses that, on the assumption in sub-paragraph (1C), would be deductible under sub-paragraph (1)(b), and\n(ii) the amount of allowable losses (other than pre-entry losses) that, on the assumption in sub-paragraph (1C), would be deductible under section 2A(1), and\n(b) for the purposes of sub-paragraph (1)(c), the deductions made under section 2A(1) may not exceed the difference between—\n(i) the total of the amounts mentioned in paragraph (a)(i) and (ii), and\n(ii) the amount of pre-entry losses deducted under sub-paragraph (1)(b).\n(1C) The assumption is that deductions under sub-paragraph (1)(b) are treated for the purposes of Part 7ZA of CTA 2010 (restrictions on obtaining certain deductions) as if they were made under section 2A(1)(b) of this Act.”",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2020/14/schedule/4/paragraph/18",
    "retrieved_at": "2026-10-29T09:01:44.314864+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."
}