Introduction Summary
1.Section 62 addresses scenarios where trade cessation artificially occurs as a result of it being transferred to a person or persons outside the scope of Corporation Tax and it can be established that this is part of a scheme or arrangement, the main purpose or one of the main purpose of which is to access ‘terminal loss relief’.
2.In such circumstances ‘terminal loss relief’ will not be available to the transferring entity and neither will carried forward losses relating to the trade be transferred to the receiving entity for set off against future profits.