This guidance note summarises significant relaxations on the use of losses impacting all companies regardless of size. It also covers an important restriction on the use of losses carried forward aimed primarily at larger companies and groups of companies with losses carried forward of greater than £5m. The restriction is set at 50% of profits.

The rules for carried-forward losses before 1 April 2017 provide in some cases that specified types of losses may only be carried forward against specific pools of profits. In other cases, there is no restriction to the type of profits that may be used for set-off purposes. For example, surplus management expenses of an investment business or investment company are carried forward against future 'total profits'.

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