Consortium relief
Consortium relief

The following Tax guidance note provides comprehensive and up to date legal information covering:

  • Consortium relief
  • Owned by a consortium
  • 90% subsidiary
  • Wholly or mainly tests
  • Members of a consortium
  • Who can claim and surrender consortium relief?
  • Direct consortium relief
  • Linked consortium relief
  • Administration of claims for consortium relief

Consortium relief is an extension of the group relief rules to allow the surrender and claim of losses between companies that are not so closely connected as to form a group but where the joint ownership of a company forms a consortium. It is sometimes referred to as 'upside down group relief' because the structure diagram of a simple consortium is more like an inverted pyramid, whereas the structure diagram of a simple group is like a pyramid.

The legislation does not make a distinction in terminology between group relief and consortium relief, but for ease of reference this note and How much consortium relief can be surrendered and claimed? use group relief when referring to group relief made between members of a loss relief group, and consortium relief when referring to group relief made in accordance with the rules explained in this note.

The Finance (No 2) Act 2017 (F(No 2)A 2017) introduced provisions reforming the rules on what companies can do with carried-forward corporation tax losses. The provisions include a new group relief (which applies to groups and consortia) for carried forward losses in respect of losses arising on or after 1 April 2017. Carried forward losses arising before 1 April 2017 cannot benefit from this relief. This Practice Note only deals with consortium relief for current year losses. For more