As part of Budget 2016, the government announced that it would restrict the amount of a company’s profits that can be offset by carried-forward losses to 50%, over an annual allowance of £5m, from 1 April 2017 while allowing greater flexibility over the use of losses incurred after that date.

After consultation, the new rules were included in September’s Finance Bill, but will apply retrospectively from 1 April 2017.

The introduction of these complex rules comes at the same time as the new corporate interest restriction rules coming into force; hot on the heels of the new anti-hybrid rules, country-by-country reporting, new tax transparency requirements, etc.