Introduction Current corporate tax loss buying rules
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.