CTM80350 - Groups: group relief: overseas permanent establishment of UK resident company

ICTA88/S403E

From 1 April 2000, there is a restriction on the losses and other amounts ( CTM80110) that can be surrendered as group relief by a UK resident company that trades through an overseas permanent establishment.

The loss etc. cannot be surrendered as group relief in so far as it:

• is attributable to the overseas permanent establishment ( CTM80355), and
• any part of the loss etc. so attributable is or represents an amount for which tax relief may be given in a foreign jurisdiction to someone other than the UK company ( CTM80360).

The restriction does not apply to losses of life assurance business.

For transitional provisions that apply to accounting periods straddling 1 April 2000 see CTM80370.