Commentary on Sections Overview Overview Section 1104: Meaning of “Chapter 7 surrenderable loss”
2869.This section defines “Chapter 7 surrenderable loss”. It is based on paragraph 16 of Schedule 13 to FA 2002.
2870.The section follows the same pattern as section 1055 (meaning of “Chapter 2 surrenderable loss”) but the restriction in subsection (2) if the claim is made by a trading company is slightly different.
2871.Section 1055(2)(b) gives relief both for the additional deduction and for the underlying expenditure. Subsection (2) denies relief for the underlying expenditure. This is because if the company has had relief under Chapter 2 it will already have had relief for the underlying expenditure in making an R&D tax credit claim under section 1055.