Restriction (s24A ITA 2007) on share loss relief (s131 ITA 2007)- how to calc

Restriction on share loss relief - how to calc

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Nice and easy question for a Thursday morning for someone, please:

I am preparing a loss relief claim under s.131 ITA 2007.  Assume it qualifies.

The loss arose in 2015-16 and I am claiming the relief in both 2015-16 and 2014-15 tax years.

The loss is far in excess of £50K.  Indeed it exceeds £100K, and any way you look at it, it exceeds 25% of adjusted income, in either 2014-15 or 2015-16 or both added together.

Q1:  Disregarding the 25% limitation, am I right in saying that the total available relief in both years combined is £50K not £100K, ie the fact that I am relieving in two years does NOT double up the cap?

Q2: Am I right that the "Adjusted income" limit is calculated by reference to 2015-16 income alone despite that some of the relief is given in 2014-15?

Q3: Had I claimed the relief ONLY in 2014-15, would I be right in saying that it is still only the 2015-16 adjusted income that fixes the cap on the relief?

Thanks

With kind regards

Clint Westwood

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