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22 October 2000
Modernisation of group relief
The changes to the group relief rules in this year's Finance Act allow groups and consortia to be established for group relief purposes through companies resident anywhere in the world. Group relief has also been extended to United Kingdom branches of non-resident companies, and the rules for the surrender of losses attributable to overseas branches of United Kingdom-resident companies have been brought into line.
The changes to the group relief rules in this year's Finance Act allow groups and consortia to be established for group relief purposes through companies resident anywhere in the world. Group relief has also been extended to United Kingdom branches of non-resident companies, and the rules for the surrender of losses attributable to overseas branches of United Kingdom-resident companies have been brought into line.
Modernisation of group relief
The changes to the group relief rules in this year's Finance Act allow groups and consortia to be established for group relief purposes through companies resident anywhere in the world. Group relief has also been extended to United Kingdom branches of non-resident companies, and the rules for the surrender of losses attributable to overseas branches of United Kingdom-resident companies have been brought into line.
The new rules apply for accounting periods ending on or after 1 April 2000. Periods straddling 1 April will be apportioned so that the changes take effect only in respect of losses arising from that date.
Companies and their advisers may find it helpful in submitting claims for group relief to have some guidance on the operation of the new sections 403D and 403E, Taxes Act 1988, which contain the rules for branch losses. The following summary outlines the basic principles of these new rules and gives examples of how they will apply in practice.
The examples represent the current understanding of the law in the various countries mentioned but should not be taken as definitive statements on the foreign law.
The changes to the group relief rules in this year's Finance Act allow groups and consortia to be established for group relief purposes through companies resident anywhere in the world. Group relief has also been extended to United Kingdom branches of non-resident companies, and the rules for the surrender of losses attributable to overseas branches of United Kingdom-resident companies have been brought into line.
The new rules apply for accounting periods ending on or after 1 April 2000. Periods straddling 1 April will be apportioned so that the changes take effect only in respect of losses arising from that date.
Companies and their advisers may find it helpful in submitting claims for group relief to have some guidance on the operation of the new sections 403D and 403E, Taxes Act 1988, which contain the rules for branch losses. The following summary outlines the basic principles of these new rules and gives examples of how they will apply in practice.
The examples represent the current understanding of the law in the various countries mentioned but should not be taken as definitive statements on the foreign law.
