CTM80136 | Groups: group relief: Schedule A losses - transitional provisions
From HM Revenue & Customs · Company Taxation Manual
ICTA88/S403 (1) and (3), ICTA88/S403ZD (3), ,
Schedule A losses brought forward from an earlier period cannot be added to the Sch A losses of an accounting period and surrendered as group relief ().
An exception to this is where, as at 1 April 1998, there are unrelieved Schedule A expenses (PIM4620). For the purposes of computing Schedule A profits or losses such expenses are treated as having been incurred on 1 April 1998. So they can be surrendered as group relief for the accounting period into which 1 April 1998 falls.
Note that this exception does not apply to Case VI losses at 1 April 1998 brought forward into Schedule A by .