Commentary

D2.234 Group relief for carried-forward losses—maximum claim and eligible losses

Corporate tax
Corporate tax | Commentary

D2.234 Group relief for carried-forward losses—maximum claim and eligible losses

Corporate tax | Commentary

Group relief for carried-forward losses—calculation for group members

D2.234 Group relief for carried-forward losses—maximum claim and eligible losses

From 1 April 2017, companies can surrender certain types of carried forward losses to another company in the same group relief group. However, it is only losses that were incurred on or after 1 April 2017 which are then carried forward to a later period that can be group relieved. Where a company's accounting period straddles 1 April 2017, the periods before and after 1 April 2017 are treated as two separate accounting periods and profits/ losses are time apportioned or (where that would produce an unreasonable result) apportioned on a just and reasonable basis1.

Group relief for carried forward losses is very similar to group relief for current year losses. Consequently the provisions detailed at D2.205–D2.210 apply equally to this relief, with any differences being noted in the relevant articles. The mechanics of the offset are also similar to group relief claims (see D2.215 and D2.216).

Maximum claim for group relief of carried forward losses

The maximum relief that can be claimed is the lower of the2:

  1.  

    •     unused part of the surrenderable amount for the overlapping period, and

  2.  

    •     difference between the claimant company's relevant maximum (D2.235) and the amount of previously claimed group relief for carried forward losses for the overlapping period3

A period is overlapping if it is common to the accounting periods of the surrendering company and the claimant company4.

When determining the unused part of

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