| Loss/relief      | BLAGAB           |
|------------------|------------------|
| I - E            |                  |
| BLAGAB trade     | Non-BLAGAB trade |
| Business Fixed   |                  |
| Capital (LTBFC)  |                  |
| and other non-   |                  |
| trading business |                  |
| Management       |                  |
| expenses         |                  | 
Adjusted BLAGAB management expenses are set against I - E income and net chargeable gains of the period. Excess expenses can only be carried forward and treated as BLAGAB expenses of the next 
period.   
Short-term business (e.g. general insurance) 
Exceptionally the general rule at CT09/S1219 could apply to expenses from the management of grandfathered assets in LTBFC or other non-trading activity. Expenses are set against income from the non-trading business in the period. Excess expenses can be:  Set off against 
total profits of the period (excluding BLAGAB policyholder share of I-E profits) 
  surrendered as 
group relief; 
 carried forward 
and set against 
| Trade losses                 |                         |
|------------------------------|-------------------------|
|                              |                         |
|                              |                         |
|                              |                         |
|                              |                         |
| Non-BLAGAB trade             |                         |
| losses (LAM07300) are        |                         |
| treated as "normal" trade    |                         |
| losses and can be:           |                         |
|                              |                         |
| A BLAGAB trade loss          |                         |
| (LAM07310) of the period     |                         |
| can be:                      |                         |
|                              |                         |
|                             |                         |
| set sideways against         |                         |
| X                            |                         |
|                              |                         |
| shareholder total profits of |                         |
| the period (i.e. non-        |                         |
| BLAGAB trade profit, -       |                         |
| profit arising in long-term  |                         |
| business fixed capital and   |                         |
| any general insurance        |                         |
| profit);                     |                         |
|                             |                         |
|                              | set against             |
| shareholder total            |                         |
| profits* of the period,      |                         |
| then any remaining           |                         |
| losses can be set            |                         |
| against shareholder          |                         |
| total profits* of the        |                         |
| previous 12 months;          |                         |
|                             |                         |
| set against shareholder      |                         |
| total profits for the        |                         |
| previous 12 months;          |                         |
|                             |                         |
|                              | surrendered as group    |
| relief;                      |                         |
|                             |                         |
| surrendered as group         |                         |
| relief;                      |                         |
|                             |                         |
|                              | carried forward and set |
| against future non-          |                         |
| BLAGAB profits.              |                         |
|                             |                         |
| carried forward and set      |                         |
| against any BLAGAB trade     |                         |
| profit of the next period.   |                         |
|                              |                         |
| *Shareholder total profits   |                         |
| include:                     |                         |
|                              |                         |
| -                            |                         |
| the shareholders' share      |                         |
| -                            |                         |
| non-BLAGAB trade             |                         |
| -                            |                         |
| profit arising from long-    |                         |
|                              |                         |
| A BLAGAB trade loss utilised |                         |
| under any of the first three |                         |
| options above requires two   |                         |
| adjustments to be made:      |                         |
|                              |                         |
|                             |                         |
| firstly the loss must be     |                         |
| -                            |                         |
| profit from any short-       |                         |
| reduced by any BLAGAB        |                         |
| non-trading deficit - see    |                         |
| S126 FA2012, then;           |                         |
|                             |                         |
| the BLAGAB management        |                         |
|                              |                         |
| expenses of the period       |                         |
| LTBFC/non-                   |                         |
| trading income of            |                         |
| the next period.             |                         |
|                              |                         |
|                              |                         |
|                              |                         |
|                              |                         |
|                              |                         |
|                              |                         |
| X                            |                         |
|                              |                         |
| Losses from any short-       |                         |
| term business such as        |                         |
| general insurance are        |                         |
| treated as "normal"          |                         |
| trade losses and can         |                         |
| be:                          |                         |
|                              |                         |
|                             |                         |
| set against                  |                         |
| shareholder total            |                         |
| profits* of the period;      |                         |
|                             |                         |
| any remaining loss           |                         |
| can be set against           |                         |
| shareholder total            |                         |
| profits of the               |                         |
| previous 12 months;          |                         |
|                             |                         |
| surrendered as               |                         |
| group relief;                |                         |
|                             |                         |
| carried forward and          |                         |
| set against future           |                         |
| profits of the short-        |                         |
| term trade.                  |                         |
| of the I - E profit;         |                         |
| profit;                      |                         |
|                              |                         |
| *Shareholder total           |                         |
| profits include:             |                         |
|                              |                         |
| -                            |                         |
| the shareholders'            |                         |
| share of the I - E           |                         |
| profit;                      |                         |
| term business fixed          |                         |
| capital;                     |                         |
| -                            |                         |
| non-BLAGAB trade             |                         |
| profit;                      |                         |
| term business.               |                         |
must be reduced (at step 4 of S76 FA2012) by the quantum of loss utilised.  
Allowable (capital) losses 
 
BLAGAB allowable (capital) losses (LAM03200) can be utilised as follows:  set against BLAGAB 
chargeable gains of the period (including deemed gains (LAM03300); 
 carried forward and 
set against BLAGAB chargeable gains of the next period; 
 the shareholder share 
of the net BLAGAB allowable loss can be set against non- BLAGAB gains (LAM03420).  
Allowable loss arising from deemed disposal 
A net allowable loss can be carried back (in full or in part) and set against net chargeable gains arising from the deemed 
- profit arising from 
long-term business fixed capital;  
- profit from any shortterm business. 
Allowable  losses not arising from BLAGAB will be set off against any chargeable gains not arising from BLAGAB.  Any excess allowable losses can be 
 Set off against any 
shareholders share of BLAGAB gains, or 
 carried forward to 
the next period and set against chargeable gains arising not arising from BLAGAB in future periods or shareholder share of any BLAGAB gains in future periods.    
under S212 TCGA (LAM03340) 
disposal in the previous two accounting periods. Any net allowable loss 
remaining is spread over 7 years. 1/7th of the net allowable loss is treated as an allowable loss of the accounting period with a further 1/7th treated as an allowable loss at the end of each succeeding accounting period. 
X 
Non-trading loan relationship deficit (loan relationships and derivatives) 
Any BLAGAB NTLR 
deficit (LAM03060) is to be used firstly against BLAGAB income and gains of the period. Any remaining deficit can be carried back for up to 3 accounting periods ending within the 12 months immediately before the deficit period. Any deficit still remaining is carried forward to the next period and treated as a deemed BLAGAB management expenses of that period. 
X 
X 
A NTLR deficit 
arising in LTBFC is treated as a "normal" non-trading deficit under CTA09/S456. The deficit can be:  set against 
shareholder total profits of the period; 
 carried back (in 
full or in part) and set against any NTLR profit(other than BLAGAB NTLR profit) of the previous 12 months; 
Non-trading deficit (Intangible assets) 
Any non-trading deficit (LAM03070) arising from an intangible asset is treated as a deemed management expenses of the period.  
When there is no I –E 
profit the shareholders' 
share of any BLAGAB non-trading deficit for the period can be group relieved under CTA10/S99. 
 surrendered as 
group relief;  
 carried forward 
and set against 
non-trading profits for future accounting periods.  
Any non-trading deficit arising in LTBFC is treated as a "normal" nontrading deficit under CTA09/S456. The deficit can be:  set against 
shareholder total profits of the period; 
 carried back (in 
full or in part) and set against any non-trading profits of the previous 12 months; 
 surrendered as 
group relief;  
 carried forward 
and set against non-trading profits for future accounting periods CTA09/S457. 
 
X 
UK property business loss 
An overall net loss arising from BLAGAB property businesses (LAM03900) is treated 
as a deemed management expense of the period. When there is no I –E 
profit the shareholders' 
share of any BLAGAB UK property business loss for the period can be group relieved under CTA10/S99 
 
X 
Capital Allowances - investment assets 
Investment capital allowances can be deducted in the BLAGAB I - E computation. S545(3) CAA2001 denies relief for investment capital allowances in non- BLAGAB. Management capital allowances are brought into account at step 3 of S76 FA2012.  
Management capital allowances can be deducted in the BLAGAB trade computation. 
Capital Allowances - management assets 
Management capital allowances can be deducted in the non- BLAGAB trade computation. 


X 
X 
Any property income loss arising from property assets in 
LTBFC is  set off under the rules in CTA10/S62 PIM4230 


X  
X 
X 
The normal capital allowances rules apply to general insurance business. See GIM4030 and CTM02350. 
S18 & S253 CAA01 allow for capital allowances on plant & machinery used in managing the investment business. 
Group relief offsets 
 
X 
The normal group relief rules apply to a claim against a non-BLAGAB 
trade profit.  
Group relief 
The shareholders' share 
of the I-E profit can be relieved by group relief 
surrender by other group companies. 
The shareholder's share 
of amounts falling within CTA/210 (d)-(g) are not available to surrender as group relief when there is an I-E profit for the period. 
 
The normal group relief rules apply to a claim against any short-term 
business profit. 
The normal group relief rules apply to a claim against any 
profits arising in LTBFC.