CTM82040 | Corporation Tax: Group relief for carried-forward losses: Restrictions for certain types of insurance company
From HM Revenue & Customs · Company Taxation Manual
If the surrendering company is a general insurance company for which the surrender period is an excluded accounting period, the following types of loss may not be surrendered as group relief for carried-forward losses:
Non-trading loss on intangible fixed assets () ()
Expenses of management of an investment company () ()
UK property business losses ( and S63(3)(a)) ()
Carried-forward trading losses and non-trading loan relationship deficits may not be surrendered as group relief either. These losses are allowed only under and and are not included in the list in of carried-forward losses that may be group relieved.
If the surrendering company is a Solvency 2 insurance company, the types of loss which may not be surrendered as group relief for carried-forward losses are as for a general insurance company above. However the loss is only restricted as far as the loss is, or expenses are, a shock loss ().
The definition of general insurance company and the definition of excluded accounting period are both found at .For the purposes of group relief for carried-forward losses, a Solvency 2 insurance company is an insurance company as defined at .