Looking for a bit of help please - I'm aware that Ltd Co capital losses can be carried forward and set off against future capital gains and to my knowledge there is little else that can be done with the losses.
On the basis that they are c/f, are there likely to be any problems with relieving the losses in the following circumstance (I ask because I know HMRC can sometimes exclude certain tax reliefs when it comes to dealing with land or property developers)....
Holding Co has 1 subsidiary only (Sub Co), 100% owned. The only income received by Holding Co has been management charges paid by the Sub Co. The Sub Co's prinicpal activity was new build, residential house building. Sub Co went into receivership last year and Holding Co's investment in Sub Co is now worthless (original cost of share cap was £X,000,000).
If the Holding Co declares capital losses on its CT600, could these be set off against capital gains if it were to make a gain on sale of land in years to come? I.e. Holding Co acquires land for £1M and sells it to a New Co for £2M? (for info, New Co and Holding Co would have common shareholders but no direct investment by one in the other). Or are there exclusions from loss relief when land is involved?
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