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Official guidance
Company Taxation Manual

CTM80500 · Consortia: group relief

  • CTM80502 · Introduction
  • CTM80510 · Application of rules
  • CTM80515 · Claims
  • CTM80520 · Claims: consent to be given
  • CTM80525 · Claims: rules limiting
  • CTM80530 · Meaning of ‘members of the consortium’ and ‘company owned by a consortium’
  • CTM80535 · 90% subsidiary
  • CTM80540 · Amount of relief: claimant is a member of the consortium: claims based on consortium condition 1
  • CTM80545 · Amount of relief: claimant is company owned by a consortium: claims based on consortium condition 1
  • CTM80550 · Extension to companies in same group as member of the consortium
  • CTM80555 · Claim by company in same group as member of the consortium: claims based on consortium condition 2
  • CTM80560 · Surrender by company in same group as member of the consortium: consortium condition 3
  • CTM80570 · Items eligible for relief: potential restriction on surrender of trading losses
  • CTM80580 · Group and consortium claims both possible: surrendering company is both owned by a consortium and a member of a group
  • CTM80585 · Group and consortium claims both possible: claimant company is both owned by a consortium and a member of a group
  • CTM80587 · Control arrangements: claimant is member of the consortium
  • CTM80588 · Control arrangements: claimant is company owned by the consortium
  • CTM80590 · Diagram showing meaning of various terms
  • CTM80600 · Arrangements to transfer the company owned by a consortium to another group or consortium
  • CTM80605 · Arrangements: disqualifying relief
  • CTM80615 · Arrangements: definitions
  • CTM80620 · Enabling arrangements
  • CTM80625 · Direct arrangements
  • CTM80630 · Date of arrangements
  • CTM80635 · Information about arrangements
  • CTM80640 · SP3/93 and ESC C10
  • CTM80670 · Example: consortium relief generally
  • CTM80675 · Example: surrender by member of the consortium and by a member of its group, overlapping periods and company joining link company’s group
  • CTM80680 · Example: claim by company owned by a consortium from a company in the same group as a member of the consortium
  • CTM80685 · Example: restriction where group claims possible
  • CTM80690 · Example: restriction where group claims are possible by companies which are not owned by the consortium
  • CTM80695 · Example: restriction where group claims are possible
  • CTM80696 · Example: restriction of surrender of trade losses where company owned by consortium has other profits
  1. Consortia: group relief: contents
  2. Consortia: group relief: claims: rules limiting

CTM80525 | Consortia: group relief: claims: rules limiting

From HM Revenue & Customs · Company Taxation Manual

CTA10/Ss138 to 149

There are a number of rules whose effect is to limit the amount of consortium relief claimed.

  • The general group relief rules about apportionment of amounts to overlapping periods in CTA10/Ss138 to 142 also apply to consortium claims (CTM80215).

  • CTA10/Ss143 and 144, broadly, limit the amounts that can be surrendered and claimed by reference to four ownership proportions of the surrendering or claimant company. See CTM80540 (claimant is a ‘member of the consortium’) and CTM80545 (claimant is ‘company owned by a consortium’) for more guidance on Ss143 and 144 respectively.

  • CTA10/S147 governs the amount of relief in a case where trade loss relief under CTA10/S37 may also be claimed by a company owned by a consortium in the period (CTM80570 and CTM80585).

  • CTA10/Ss148 and 149 govern the amount of relief in a case where group relief may be available from a fellow group member in addition to consortium relief (CTM80580 and CTM80585).

  • CTA10/Ss145 and 146 put limits on the amount that can be claimed or surrendered by a company in the same group as a member of the consortium (CTM80555 and CTM80560).

  • For claims for accouting periods beginning on or after 12 July 2010, CTA10/Ss146A and 146B halve the amount of relief available where arrangements are in place to prevent the member of the consortium from controlling the company owned by the consortium, and the main purpose, or one of the main purposes of the arrangements is to enable the member of the consortium to gain a tax advantage (see CTM80587 and CTM80588).

  • CTA10/S137(7) deals generally with the exclusion of double allowances (CTM80405).

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