I move amendment No. 78:
In page 113, lines 27 to 37, to delete "subsection (4) and substitute the following:
"(4) So much of the abandonment losses, if any, incurred by a person on or before the day on which he permanently discontinues to carry on a petroleum trade (hereafter in this subsection referred to as ‘the first-mentioned trade') as would not, apart from this subsection, be allowed against, or treated as reducing, his or any person's income or profits, shall be treated as incurred by him in the first chargeable period of the first petroleum trade (hereafter in this section referred to as ‘the new trade') to be carried on by him after the permanent discontinuance of the first-mentioned trade as a trading expense of the new trade.".
Subsection (4) of section 81 ensures that where a company or unincorporated trader is unable to fully use up his tax relief in respect of abandonment expenditure before petroleum trade ceases, the unused balance can be carried forward or set off against the income of any new petroleum trade the company or trader may subsequently carry on. The amendment replaces the existing subsection (4) with a revised version of the subsection in order to clarify the intention of the subsection. While ensuring that unused balances of relief for abandonment expenditure may be carried forward to new trade, the revised subsection also eliminates the possibility of double relief in respect of that expenditure.