CTM82170 | Reform of Corporation Tax loss relief: Group relief for carried-forward losses: Payment made for loss

CTA10/S188FA

Any payment made under an agreement by the claimant company to the surrendering company in respect of group relief for carried-forward losses up to the amount of the loss is ignored for Corporation Tax purposes. The payment is not taken into account in computing the profits or losses of either company and it is not treated as a distribution.