Taxes Consolidation Act 1997 Schedule 32 paragraph 17

Relief in Respect of Losses or Deficiencies Within Case IV or V of Schedule D

Paragraph 17 of Schedule 32 provided transitional relief for Case IV and Case V losses and deficiencies that arose before the introduction of corporation tax on 6 April 1976 and that had not been fully relieved under the former income tax rules.

• Where a company had an unrelieved Case IV loss or Case V deficiency (including associated capital allowances) from 1975–76 or an earlier year, the unrelieved amount was treated as a trading loss and could be relieved under paragraph 16 against the company's corporation tax income of the same description.
• Relief under paragraph 16 operated by giving a credit against corporation tax payable, calculated by applying the standard credit rate to the amount of the loss or capital allowance; any unrelieved balance could be carried forward to subsequent accounting periods.
• Case IV losses (with associated capital allowances) could only be set against Case IV income chargeable to corporation tax, and Case V deficiencies (with associated capital allowances) could only be set against Case V income chargeable to corporation tax.
• Any deficiency or deemed loss that could not have been carried forward or set against profits for income tax purposes under the former rules was excluded from relief under this paragraph.