Introduction Equity holders Overview Section 100: Meaning of “trading loss”
354.This section explains which trading losses are available for relief. It is based on section 403ZA of ICTA.
355.Subsection (1) is the link to the basic rule in section 99(1)(a).
356.Subsection (2) excludes from the available losses:
	losses made in a trade carried on wholly outside the United Kingdom (the profits of which were historically charged to tax under Schedule D Case V); and
	non-commercial losses for which relief would not be available to the surrendering company under the loss relief rules (see Part 4).
357.This section does not rewrite the requirement in section 403ZA(1) of ICTA that a trading loss is calculated in the same way as a loss within section 393A of ICTA. This is because the requirement is already rewritten in section 47 of CTA 2009.