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Basics of group relief: Part 1

22 January 2024 / Andy Tall
Issue: 4921 / Categories: Comment & Analysis , group relief , Losses , Companies
Basics of group relief: Part 1

Key points

  • Group relief is a corporation tax relief allowing a company to surrender non-capital tax losses to another company in the same ‘group’.
  • Definition of ‘company’ under CTA 2010 s 1121 ‘group’ under CTA 2010 s 151 and s 1154 and the 75% test.
  • It is important to know when a group is or is not formed to establish the availability of group relief.
  • Where a company is in a capital gains group it can surrender a capital loss against a chargeable gain in the claimant company.
  • CTA 2010 Chapter 5A allows a company to surrender brought forward losses in a similar fashion to group relief under Chapter 5.
  • A claim for group relief must be made in a return and HMRC takes the view that the surrendering company must submit its tax return prior to the claimant company.

Group relief is a...

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