How much group relief can be surrendered and claimed?
How much group relief can be surrendered and claimed?

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

  • How much group relief can be surrendered and claimed?
  • Claimant priority rules
  • General limitation on amount of group relief
  • Unused part of surrenderable amounts
  • Unused part of surrenderable amounts: example
  • Step 1—determine surrenderable amount for the current claim's overlapping period
  • Step 2—determine prior surrenders for the overlapping period
  • Step 3—result
  • Unrelieved part of total profits
  • Time apportionment unjust or unreasonable

The maximum amount of group relief that a company (the claimant company) can claim in any given accounting period (the claim period) is broadly the lower of its available profit and the available loss of the surrendering company. However, this amount is limited by:

  1. the claimant priority rules, which determine how the various loss and expense reliefs available to the claimant company are to be used, and

  2. the general limitation on the amount of group relief to be given, which imposes a maximum amount of group relief that can be claimed based on the other uses of the loss in question and the available profits in the claimant company

These limitations are explained in this note. For details of the types of losses that are eligible for group relief, see: Group relief—types of losses that can be surrendered

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 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 group relief for current year losses. For more on group relief for carried forward losses, see Practice Note: