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Official guidance
Company Taxation Manual

CTM81500 · Groups: group relief: surrendering company not UK resident: periods up to 27 October 2021

  • CTM81502 · Groups: group relief: surrendering company not UK resident: outline: periods up to 27 October 2021
  • CTM81505 · Groups: group relief: surrendering company not UK resident: companies affected
  • CTM81510 · Groups: group relief: surrendering company not UK resident: amount of the loss: overview
  • CTM81515 · Groups: group relief: surrendering company not UK resident: amount of the loss: the equivalence condition
  • CTM81520 · Groups: group relief: surrendering company not UK resident: amount of the loss: the EEA tax loss condition
  • CTM81525 · Groups: group relief: surrendering company not UK resident: amount of the loss: the qualifying loss condition
  • CTM81530 · Groups: group relief: surrendering company not UK resident: amount of the loss: the qualifying loss condition: current & previous periods
  • CTM81535 · Groups: group relief: surrendering company not UK resident: amount of the loss: the qualifying loss condition: future periods
  • CTM81540 · Groups: group relief: surrendering company not UK resident: amount of the loss: the qualifying loss condition: not otherwise given
  • CTM81545 · Groups: group relief: surrendering company not UK resident: amount of the loss: the precedence condition
  • CTM81550 · Groups: group relief: surrendering company not UK resident: amount of the loss: the unallowable loss rule
  • CTM81555 · Groups: group relief: surrendering company not UK resident: amount of the loss: unallowable losses and arrangements
  • CTM81560 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation
  • CTM81565 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: residence
  • CTM81570 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: accounting periods
  • CTM81575 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: capital allowances
  • CTM81580 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: intangible assets
  • CTM81585 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: loan relationships & derivative contracts
  • CTM81590 · Groups: group relief: surrendering company not UK resident: amount of the loss: comparison of UK and overseas loss
  • CTM81591 · Groups: group relief: surrendering company not UK resident: amount of the loss: comparison of UK and overseas loss: information to be provided by claimant company
  • CTM81595 · Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: life assurance companies
  • CTM81600 · Groups: group relief: surrendering company not UK resident: claims in respect of overseas losses of non resident companies: overview
  • CTM81605 · Groups: group relief: surrendering company not UK resident: claims in respect of overseas losses of non-resident companies: enquiries
  • CTM81610 · Groups: group relief: surrendering company not UK resident: examples: the precedence condition
  • CTM81620 · Groups: group relief: surrendering company not UK resident: example: the qualifying loss condition
  • CTM81625 · Groups: group relief: surrendering company not UK resident: examples: comparison of UK and EEA loss
  • CTM81506 · Groups: group relief: surrendering company not UK resident: commencement
  1. Groups: group relief: surrendering company not UK resident: periods up to 27 October 2021: contents
  2. Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: loan relationships & derivative contracts

CTM81585 | Groups: group relief: surrendering company not UK resident: amount of the loss: UK recomputation: loan relationships & derivative contracts

From HM Revenue & Customs · Company Taxation Manual

In order to quantify the loss eligible for relief, the foreign loss is to be recomputed in accordance with UK principles, (CTM81560).

All of the computational rules in Part 5 CTA 2009 need to be applied to arrive at profits or losses on loan relationships, and similarly the computational rules in Part 7 CTA 2009 need to be applied to arrive at profits or losses on derivative contracts.

This takes in not only the basic computational rules (found at CTA09/PT5/CH3 for loan relationships, and CTA09/S595 for derivative contracts) but in particular will include:

  • Regulations made under powers contained in the loan relationships or derivative contracts legislation, for example the Disregard Regulations dealing with derivative contracts that hedge assets or liabilities.

  • Any applicable special rules, such as anti-avoidance legislation.

The Corporate Finance Manual provides details of how to compute profits and losses arising on loan relationships and derivative contracts. Guidance on loan relationships is at CFM30000 onwards, and on derivative contracts at CFM50000 onwards.

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