CTM80230 - Groups: group relief: overlapping period: surrenderable amount and claimant’s profits

ICTA88/S403A(3), ICTA88/S403B, ICTA88/S403D(2)

For the purposes of Section 403A ( CTM80215) the surrenderable amount for the overlapping period ( CTM80225) is that part of its total losses and other amounts available for surrender ( CTM80110) for the whole accounting period which is apportioned to the overlapping period.

The claimant’s total profits for the overlapping period is that part of its total profits for the whole accounting period which is apportioned to the overlapping period. Where the claimant company is not resident in the UK but is claiming group relief against profits of a permanent establishment in the UK ( CTM80310), the profits to be apportioned are those of the permanent establishment within the charge to CT.

The usual method of apportionment is time apportionment. However some other just and reasonable apportionment may be used if time apportionment would be unjust or unreasonable, see CTM80260.