30.The general concept is that losses brought forward or after a change in ownership should be allowable only to the company and trade in which they occurred.
31.Section 39 of CTA 2010 provides that if a company sells its trade to a company that is not within the same 75% ownership then the cessation rules apply and the losses do not transfer.
32.Part 14 of CTA 2010 deals with realised losses where there is a change in ownership of a company (and where other circumstances apply). If the Part applies losses arising prior to the change are no longer available for periods after the change in ownership.
Introduction Current corporate tax loss buying rules