Commentary

D7.521 Group relief

Corporate tax
Corporate tax | Commentary

D7.521 Group relief

Corporate tax | Commentary

D7.521 Group relief

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

The general principle throughout the life assurance provisions of the Corporation Tax Acts is that group relief properly relates to the shareholders' trading profit or loss, not the policy holders' share of the company's profits. As a result group relief may be claimed only against the shareholders' share of relevant profits1. The corollary to this is that while a trading loss may be surrendered as group relief (representing the commercial

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