Taxes Consolidation Act 1997 Schedule 25C

Determination of amount of relief to be treated as referable to specified reliefs as respects relief carried forward from tax year 2006 to tax year 2007

Schedule 25C set out the rules for splitting reliefs carried forward from the tax year 2006 into the tax year 2007 between amounts attributable to specified reliefs and amounts attributable to other (unspecified) reliefs, so that the restriction on specified reliefs in Chapter 2A of Part 15 could operate correctly from 2007 onwards.

• Reliefs carried forward from 2006 to 2007 were apportioned between specified and unspecified reliefs using a formula based on the taxpayer's use of each type of relief over the preceding four years (2003 to 2006), with all reliefs brought forward into 2003 from earlier years disregarded.
• The apportionment applied separately to four categories: excess trading capital allowances carried forward under section 304, trading losses carried forward under section 382, excess rental capital allowances carried forward under section 305, and rental losses carried forward under section 384.
• Taxpayers could apply in writing to Revenue for an alternative apportionment period (longer or shorter than four years, but always including 2006), and Revenue's refusal of the application could be appealed to the Appeal Commissioners within 30 days.
• This Schedule is now spent, as its provisions related solely to the transitional allocation of reliefs into the tax year 2007.