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

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 CTA10/S269ZD (CTM05010).

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 CTA10/S188BB(1) and FA12/S124B (CTM82020), (CTA10/S188CD(a)), or

• the company makes a claim under CTA09/S458(1) for non-trading loan relationship deficits not to be set against non-trading profits (CFM32040), or under section 45(4A) or section 45B(5) for trading losses not to be set against trading profits (CTM04135) (CTA10/S188CD (b)-(d)).

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