Commentary

D2.210 Group relief—effective use of losses

Corporate tax
Corporate tax | Commentary

D2.210 Group relief—effective use of losses

Corporate tax | Commentary

D2.210 Group relief—effective use of losses

It is possible to use losses in several ways including:

  1.  

    (a)     current year loss relief and then carry back (D1.1104)

  2.  

    (b)     group relief (current year and carry forward), and

  3.  

    (c)     carry forward (D1.1106, D1.1108)

When using losses, it is important to obtain relief at the highest rate of tax. It is also typically beneficial to use the losses up sooner rather than later, though each case should be considered separately.

From 1 April 2017, there may be two 'pools' of losses — those that can be carried forward for offset against future total profits and those that are restricted (eg pre 1 April 2017 losses, or non-qualifying post 1 April 2017 losses can only be carried forward for offset against future trading profits). It may be sensible to consider using the losses that are restricted in priority to other losses carried forward. This may ensure greater flexibility going forward with the remaining losses.

Prior to 1 April 2015, it was also important for all companies to consider the effective marginal rates they were paying in the UK (marginal rates being the rate that was effectively paid on a

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