CTM80110 | Groups: group relief: what can be transferred between group members?
From HM Revenue & Customs · Company Taxation Manual
, (2), (3), and (4)
Starting at , the legislation sets out the losses and other reliefs that may be surrendered as group relief. There is a more detailed description of each of these losses and other amounts in sections to S104.
provides that the following can be surrendered and claimed as group relief:
a. a trading loss - loss available for relief explained in ()
b. a capital allowances excess - meaning explained in ()
c. non-trading deficit on loan relationship - ()
d. amounts allowable as qualifying charitable donations ()
e. a UK property business loss - explained in ()
f. management expenses - explained in ()
g. a non-trading loss on intangible fixed assets - explained in ()
Trading losses, excess capital allowances, and non-trading deficits on loan relationships (a to c above) may be surrendered in full. This is regardless of whether the surrendering company has other profits against which the losses and other amounts might have been set off.
Qualifying charitable donations, UK property business losses, management expenses, and non-trading losses on intangible fixed assets (d to g above) may only be surrendered to the extent that they, in aggregate, exceed the ”profit related threshold” (or ‘gross profit’ for surrender periods ended before 20 March 2013). For more detail about this see and (3A) ().