Introduction Overview Overview Section 680: Restriction on the carry forward of non-trading deficit from loan relationships
2115.This section restricts relief for the company’s non-trading deficit on its loan relationships in cases in which this Chapter applies. It is based on section 768B of, and paragraph 9A of Schedule 28A to, ICTA.
2116.Debits and deficits have different functions in the loan relationships regime, therefore this Chapter imposes different restrictions on them.
2117.Section 574 of CTA 2009 provides that non-trading credits and debits from derivative contracts are to be brought into account as if they were non-trading credits or non-trading debits for the purposes of Part 5 of CTA 2009 in respect of loan relationships of the company. The reference to that section in section 768B(10) of ICTA is otiose. Subsection (1) therefore omits it.