UT (Tax & Chancery) UT-2024-000113 - [2025] UKUT 00165 (TCC)

Schedule 1A to this Act shall apply as respects any claim or election which—

S.42(11A) TMA imports Schedule 1B TMA as having effect for “certain claims for relief involving two or more years of assessment”. Schedule 1B is headed “Claims for relief involving two or more years”.

Paragraph 2 of Schedule 1B TMA addresses standalone claims for loss relief in general terms. It does not distinguish between different types of loss relief and does not limit its application to only certain types of relief. The ‘certain claims’ to which it applies (by virtue of section 42(11A)) are specified and identified in paragraph 2(1): claims for carried back loss relief for the earlier year. The paragraph provided, so far as relevant:

“2.—

(1)

This paragraph applies where a person makes a claim requiring relief for a loss incurred or treated as incurred, or a payment made, in one year of assessment (“the later year”) to be given in an earlier year of assessment (“the earlier year”).