OT21053 | Corporation Tax Ring Fence: Losses and Group Relief: Group Relief

CTA10\S305(1)

Under CTA10\S305(1) group relief is to be allowed against the claimant company’s ring fence profit only to the extent that the loss surrendered arises from ring fence activities.

HMRC take the view that where a company has a ring fence profit and a non ring fence loss, the company may surrender the downstream loss to another downstream company which is a member of the same group.

Downstream means all operations taking place after crude oil is produced, such as refining, and marketing.

Group relief for carried forward losses was introduced with effect from 1 April 2017 (CTA10/PART5A). CTA10/S305(1A) prevents group relief for carried-forward losses from being allowed against a company’s ring fence profits.