CTM82515 | Corporation Tax: Group relief for carried-forward losses: Consortia: Restrictions general

From HM Revenue & Customs · Company Taxation Manual

General restriction on relief for carried-forward losses

The group relief for carried-forward losses available to the claimant company is subject to the general restriction on relief for carried-forward losses as set out in ().

Additionally, 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)).

Further restrictions apply depending on whether the claim is made under conditions 1 and 2, or 3 and 4.