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to FA00, the group relief rules (CTM80100 onwards) applied only to bodies corporate resident in the UK (ICTA88/S413 (5) repealed by FA00).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.