Commentary

D2.236A Consortium relief for carried forward losses—basic calculation

Corporate tax
Corporate tax | Commentary

D2.236A Consortium relief for carried forward losses—basic calculation

Corporate tax | Commentary

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

D2.236A Consortium relief for carried forward losses—basic calculation

Consortium relief for carried forward losses is a form of group relief for carried forward losses.

A claim for consortium relief for carried forward losses may be made if the consortium owned company is able to surrender any of the losses detailed at D2.234.

The calculation of group relief and consortium relief claims for carried forward losses are very similar and the provisions detailed at D2.234, D2.235 apply equally to the calculation of consortium relief for carried forward losses.

As for group relief claims for carried forward losses, both the claimant and the surrendering company must be either a UK resident company or a non-UK resident company within the charge to corporation tax (prior to 5 July 2016 this second condition was a non-UK resident company trading in the UK through a permanent establishment)1.

The mechanics of offset for consortium relief for carried forward losses are virtually identical to consortium relief for current year losses (D2.230–D2.232). They are summarised

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