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).