Commentary

D2.231 Consortium relief for current year losses—overlapping accounting periods

Corporate tax
Corporate tax | Commentary

D2.231 Consortium relief for current year losses—overlapping accounting periods

Corporate tax | Commentary

D2.231 Consortium relief for current year losses—overlapping accounting periods

Where the accounting periods of the claimant company and the surrendering company do not overlap, consortium relief is further restricted.

The amount of relief available is initially calculated as for group claims (D2.216), but then is further restricted by deeming a current year trading loss claim to have been made (see D2.330).

This restricted amount is applied1:

  1.  

    •     in the case of a claim by a member of the consortium, to the surrenderable amount for the overlapping period

  2.  

    •     in the case of a claim by a consortium company, to its total profits

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