CTM80143 - Groups: group relief: order of relief for amounts which can be surrendered
ICTA88/S403 (3)
Excess charges, Schedule A losses, management expenses and
non-trading losses on intangible fixed assets can be surrendered as
group relief only to the extent that they exceed the surrendering
companies other profits of the accounting period (
CTM80142) (or in the case of a
subsidiary resident in another European Economic Area territory
meet the conditions at
CTM80500 onwards).
Where a surrendering company has more than one of these types
of amount available for surrender, ICTA88/S403 (3) directs that the
order of surrender is:
- first, charges, then
- Schedule A losses, then
- management expenses, and finally
- non-trading losses on intangible fixed assets.
The legislation does not specify the order of surrender of trade losses, excess capital allowances or non-trading loan relationship deficits. The surrendering company is free to choose which of these it surrenders in what order.
