CH82282 | Penalties for Inaccuracies: Calculating the penalty: Potential lost revenue Corporation Tax Group Relief or S458 CTA10: Potential lost revenue
From HM Revenue & Customs · Compliance Handbook
This guidance applies to returns and documents with a filing date on or after 1 April 2009 where the return covers a tax period beginning on or after 1 April 2008. See CH81011 for full details.
When calculating potential lost revenue (PLR), ignore the following reliefs.
Group Relief (but see also CH82341 where the inaccuracy results in overstatement of group losses).
Relief deferred under Section 458(4) & (5) CTA10 (relief in case of repayment or release of loan).
Note: Additional relief under Section 458 (1) to (3) that can be deducted from the additional S455 charge in the inaccurate return reduces the PLR on which a penalty may be due, but relief that is deferred to another accounting period under Section 458(4) & (5) does not reduce the PLR.
Exceptions to this are
a penalty may still be charged on an inaccurate claim to relief
Group Relief claims where the inaccuracy has the effect of creating or increasing an aggregate loss recorded for a group of companies, see CH82341.
For an example of