GNT 50: Retention of Losses Post Merger

This Guidance Note sets out the criteria for retaining tax losses following a change in ownership. The provisions in Part 14 CTA 2010 contain the corporation tax loss-buying rules.

These rules were introduced primarily to counter loss-buying, and concern the acquisition of a company for its unrelieved trading losses or management expenses. However, they apply regardless of whether the access to tax losses was a motivation in the acquisition.

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