Part 4: Income tax, corporation tax and capital gains tax Section 37: CFC charge: tax avoidance involving carried-forward losses Background note
The tax avoidance involving loss carried-forward rules in Part 14B CTA 2010 (introduced by Finance Act 2015) are anti-avoidance rules which are designed to prevent groups entering into tax planning arrangements to access losses carried-forward from previous accounting periods.
	The amendments to the loss carried-forward rules in this section ensure that arrangements which involve a deduction which reduces or eliminates a CFC charge are within the scope of the loss-carried forward rules. This ensures that Part 14B has the effect that was intended when it was originally introduced.