BIM64395 - Private finance initiative (PFI): ICTA88/S413: group relief
In many PFI projects the private sector operator is a consortium company. That is:
- a directly held company owned by the consortium members, or
- a company owned 90% by a consortium holding company as defined by ICTA88/S413 (3)(b).
Where losses arise in a consortium company, group relief will be
available where the consortium company is a 'trading company', that
is 'a company the business of which consists wholly or mainly in
the carrying on of a trade' (see
BIM64385).
If a consortium company is a 'trading company', any Schedule
A losses (as from 1 April 1998) will be capable of being
surrendered as consortium relief assuming that all the other
relevant conditions are met.
