CTM82060 | Corporation Tax: Group relief for carried-forward losses: Conditions for a claim
From HM Revenue & Customs · Company Taxation Manual
, ,
A claim for group relief for carried-forward losses can be made where the surrendering company and the claimant company are in the same group. These rules are equivalent to those currently in ().
The claimant company can make a claim for relief in an accounting period (the ) for all or part of the surrenderable loss or other amounts of one or more surrendering companies if:
the surrendering company consents to the claim,
there is an , and
the is met during the overlapping period ().
The claimant company cannot make a claim where:
full relief has not been given against total profits for its own carried-forward losses of the type listed under and , (CTA10/S188CD(a)), or
the company makes a claim under for non-trading loan relationship deficits not to be set against non-trading profits, or under section or section for trading losses not to be set against trading profits (CTA10/S188CD (b)-(d)).