BIM64395 - Private finance initiative (PFI): ICTA88/S413: group relief

In many PFI projects the private sector operator is a consortium company. That is:

  1. a directly held company owned by the consortium members, or
  2. 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.