CTM80300 - Groups: group relief: the international aspect: overview
ICTA88/S402 (2), (2A), (3A) and (3B), ICTA88/S403D, ICTA88S403E
Prior to FA00, the group relief rules (
CTM80100 onwards) applied only to bodies
corporate resident in the UK (ICTA88/S413 (5) repealed by FA00).
As from 1 April 2000:
- the group relief rules apply to all bodies corporate within the charge to CT ( CTM80150),
- there are special rules ( CTM80305) concerning permanent establishments and where a loss or other amount, which might otherwise be surrendered as group relief, may be the subject of tax relief in a foreign jurisdiction,
- a group relationship (CTM80150) may be established by reference to a company resident anywhere in the world.
See Press Release PR27/99 concerning the formation of a group
relationship before 1 April 2000 by reference to a company resident
in the European Union or European Economic Area (EEA).
For transitional provisions that apply to accounting periods
straddling 1 April 2000 see
CTM80370.
For dual resident companies see
CTM34500 onwards.
As from 1 April 2006 the group relief rules are extended to
allow for the surrender of the losses of a foreign subsidiary
resident in the EEA to its UK parent, subject to certain
restrictive conditions – see
CTM80500 onwards.
