The Partnerships (Restrictions on Contributions to a Trade) Regulations 2006
Sections 117, 118ZB and 118ZE of the Income and Corporation Taxes Act 1988 contain restrictions on the extent to which limited partners, members of a limited liability partnership and non-active partners can set off their share of a partnership’s trading losses against their other income or gains (commonly called “sideways loss relief”). Section 79 of the Finance Act 2005 supplements these provisions by giving the Commissioners for Her Majesty’s Revenue and Customs a regulatory power to exclude amounts of any description specified in the regulations when computing the individual’s capital contribution to the trade, in respect of a film-related loss.