Sole trader's loss in the first year of trading: early trade losses relief (ITA 2007 ss.72-73)
Marisol was employed as an engineer until 5 April 2026, earning a salary of about £58,000 in each of the tax years 2023/24, 2024/25 and 2025/26. On 6 April 2026 she started trading as a sole trader, on a commercial basis and with a view to profit. She expects a trading loss of £30,000 for 2026/27, her first tax year of trading, and has no other income in that year. She wants to set the loss against her earliest available income. Assume that no cap or other restriction on income tax reliefs limits her claim.
Which relief allows the loss to be set against her 2023/24 employment income, and how does it operate?
Choose one answer to see the reasoning.
Worked answer
Correct answer C: Early trade losses relief, which deducts the loss from her net income of the three tax years before the loss-making year, earliest first (2023/24).
THE RULE TO REMEMBER
A trading loss in the first four tax years of a trade can be carried back against net income of the three preceding tax years, earliest first (ITA 2007 ss.72-73).
Sole trader's loss in the first year of trading: early trade losses relief (ITA 2007 ss.72-73)
Early trade losses relief under s.72 ITA 2007 is available where an individual makes a trading loss in the tax year in which the trade is first carried on, or in any of the next three tax years. Marisol's loss arises in 2026/27, the first tax year of her trade, so she qualifies. The claim deducts the loss in calculating her net income for the three tax years before the loss-making year (s.72(2)): 2023/24, 2024/25 and 2025/26. Section 73 sets the order: the loss is deducted first from the earliest of those three years, then the next, then the latest. Her £30,000 loss is therefore set against her 2023/24 employment income first, and because that income exceeds the loss, it is fully used in that year. The claim must be made by the first anniversary of the normal self-assessment filing date for 2026/27 (s.72(3)).
Why A is wrong: Relief against general income under s.64 covers only the loss-making year and the previous tax year, not three years back.
Why B is wrong: Carry-forward relief under s.83 is set only against later profits of the same trade, and it cannot reach 2023/24.
Why D is wrong: Section 73 requires the loss to be set against the earliest of the three years first, not the latest.
Why E is wrong: Terminal loss relief applies when a trade ceases; ending her employment is not the cessation of a trade.
A little more practice done.
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