Commentary

D2.261 Group relief—UK companies with overseas permanent establishment losses

Corporate tax
Corporate tax | Commentary

D2.261 Group relief—UK companies with overseas permanent establishment losses

Corporate tax | Commentary

D2.261 Group relief—UK companies with overseas permanent establishment losses

Specific provisions apply1 which broadly align the rules for the surrender of losses attributable to overseas permanent establishments of UK companies with those applying to UK permanent establishments of non-resident companies (see D2.260).

Where a UK resident company has entered into an election to exempt the results of its overseas permanent establishments from corporation tax (see D4.801), the losses from the company's overseas permanent establishments will not be available for group relief. If no election has been made, then the rules explained below apply2.

A loss or other amount of a UK-resident

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