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Official guidance
Corporate Finance Manual

CFM32000 · Loan relationships: taxing and relieving provisions

  • CFM32010 · Overview
  • CFM32020 · Loan relationships: trading credits and debits
  • CFM32030 · Loan relationships: non-trading profits and deficits
  • CFM32040 · Loan relationships: non-trading deficits: carry forward
  • CFM32045 · Loan relationships: non-trading deficits: carry foward - Examples
  • CFM32050 · Loan relationships: non-trading deficits: claims for set-off against profits of the same or earlier periods
  • CFM32060 · Loan relationships: non-trading deficits: claims for set-off against profits of the same period
  • CFM32070 · Loan relationships: non-trading deficits: claims for set-off against profits of an earlier period
  • CFM32080 · Loan relationships: non-trading deficits: claims for set-off against profits of an earlier period: example
  • CFM32090 · Loan relationships: non-trading deficits: group relief
  • CFM32100 · Loan relationships: non-trading deficits: pre-trading expenditure
  • CFM32110 · Loan relationships: Non-UK resident companies starting to carry on a UK property business
  1. Loan relationships: taxing and relieving provisions: contents
  2. Loan relationships: non-trading deficits: group relief

CFM32090 | Loan relationships: non-trading deficits: group relief

From HM Revenue & Customs · Corporate Finance Manual

Group and consortium relief claims

Companies can transfer losses and certain deficits to companies in the same group relationship by means of group or consortium relief.

In particular a group relief or consortium claim can be made under:

  • CTA09/PT5 in respect of deficits from the current period

  • CTA10/PT5A in respect of carried forward losses (post-2017 losses only)

A group or consortium relief claim falls under the general rules for group and consortium relief in CTA10/PT5. See CTM80000 for guidance on groups and consortia.

Restriction of consortium relief

In some circumstances there is a restriction to debits for bad debts or impairment losses where a company has had consortium relief. There may also be a restriction on the amount of the group relief that a company can claim if it has already had bad debt debits or impairment losses, in earlier years from a loan relationship with the consortium member surrendering group relief. There are details at CFM34000.

Group relief

There is no similar restriction on group relief arising in a group situation, as group companies cannot have impairment losses relief because they are connected (CFM35000).

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