Taxes Consolidation Act 1997 Schedule 32 paragraph 19

Capital Gains Tax Losses Accruing before 6th April, 1976

Paragraph 19 of Schedule 32 provides transitional relief for capital gains tax losses that accrued before 6 April 1976, allowing them to be carried forward and treated as allowable losses for corporation tax purposes.

• Applies to allowable capital gains tax losses from the years of assessment 1974–75 and 1975–76.
• Relief is available only to the extent that the losses could not be set against chargeable gains under capital gains tax in those years.
• Unrelieved losses are treated as if they were allowable losses accruing to the company while within the charge to corporation tax.
• The effect is to preserve pre-corporation-tax capital losses and allow them to be carried forward against the company's chargeable gains for corporation tax purposes.