11 July 2019 – Responding to the earlier consultation, HMRC has amended the proposals for BLAGAB capital losses following concerns raised by the life insurance industry that policyholders could have been impacted.  It is now proposed that there is no restriction of BLAGAB losses offset against BLAGAB gains.  The 50% restriction will apply to non-BLAGAB losses, including where the shareholders’ share of BLAGAB gains is reduced by non-BLAGAB losses, with effect from 1 April 2020.  A single £5m deductions allowance can be allocated between the existing Corporate Income Loss Restriction and the new Corporate Capital Loss Restriction.