CTM80345 | Groups: group relief: UK permanent establishment of non-resident company - amounts which can be surrendered
From HM Revenue & Customs · Company Taxation Manual
and &
For general guidance about the surrender as group relief of losses and other amounts of a UK permanent establishment of a non-resident company see .
does not overtly limit what types of amount can be surrendered (). However S107(3) requires that a loss or other amount must be ‘attributable to activities of the surrendering company in respect of which it is within the charge to corporation tax’.
So if profits from the activity would not fall within and , a loss or other amount attributable to the activity cannot be surrendered as group relief, notwithstanding it falls into one of the categories set out in .