Consortium relief

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

  • Consortium relief
  • Consortium terminology
  • Owned by a consortium
  • Extended meaning of company owned by a consortium
  • Practical implications of the extended meaning
  • Members of a consortium
  • Who can claim and surrender consortium relief?
  • Direct consortium relief
  • Linked consortium relief
  • Changes to the location of the link company
  • More...

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 Practice Note: 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 Practice Note.

Previously, consortium relief was only available in respect of current year losses. However, since 1 April 2017 (and only for losses arising on or after that date), carried-forward losses can be surrendered as consortium relief (subject to certain conditions and anti-avoidance measures). These rules are similar to the rules for surrender of current year losses and are considered further in Practice Note: Corporation tax loss relief for carried-forward losses—Group relief for carried-forward losses. This Practice Note only deals with

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