Corporate Losses and Research Reliefs
Current corporation-tax loss reliefs, ownership restrictions and examinable R&D regimes.
How to study the ATT Qualification
Use Finance Act 2025 for the 2026 tax papers, complete the three foundational CBEs early, apply professional ethics throughout and concentrate option practice on the one paper you will enter.
Core concepts
Concept 1
Corporate losses must be identified by source, period and available claim route.
Exam cue: Create a loss memorandum by source and period.
Concept 2
Group or ownership changes can restrict the use of losses.
Exam cue: Test claim limits and change-of-ownership restrictions.
Concept 3
Research relief depends on the current post-April 2024 and R&D-intensive company rules in scope.
Exam cue: Separate qualifying R&D expenditure from the mechanism delivering relief.
Risk pitfalls and guardrails
Combining all losses into one unrestricted pool.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Using superseded R&D rules.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Ignoring claim deadlines or evidence.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Memory anchors
Loss ledger
Track source, amount, period, use and balance.
Relief order
Choose current, carry-back, group or carry-forward treatment as permitted.
Ownership change
Test whether anti-avoidance restricts historic losses.
R&D current
Use the regime examinable for post-April 2024 expenditure.
Evidence
Support qualifying activity and expenditure contemporaneously.
Checkpoint rule
Do the check-up only after you can summarize each concept in one sentence and identify one dangerous pitfall from memory.
Knowledge Check (after reading)
Short check-up to confirm understanding of this module.
Check-up Questions
A company has a £70,000 trading loss and £50,000 current-period property profit. It claims current-period relief. How much trading loss remains?
A company carries a £1.2 million loss forward and has £2 million future profits. Ignoring group matters, why must the deductions allowance be checked?
Answer all questions to submit.
Next step personalized recommendations
Continue learning
Move forward only after this module is stable.
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