CTM80445 - Groups: group relief: example: surrender of excess management expenses

In the year ended 31 December 2002 Company U is a 75% per cent subsidiary of Company V, which is a group holding company. Both companies make up their accounts to 31 December. The accounts and computations of the companies for the 12 months accounting period to 31 December 2002 show the following.

Company V
Management expenses disbursed within year (ICTA88/S75 (1))£5,000
Management expenses brought forward (ICTA88/S75 (3))£500
Schedule A income£800
Profits & gains from non-trading loan relationships£3,000
Company U
Trading profits£1,000
Profits & gains from non-trading loan relationships£500
Charges paid£200

Company U claims group relief from Company V, with the consent of Company V. Group relief is limited to the smaller of:

  • Company V's excess of management expenses over the total profits for the accounting period ( CTM80142), and
  • Company U's total profits as reduced by charges paid ( CTM80400).

Company V's excess of management expenses over the total profits for the accounting period is £1,200. Under ICTA88/S403ZD (4) for group relief purposes management expenses do not include amounts carried forward from earlier periods. So, in this case, the £500 management expenses brought forward from the previous accounting period are disregarded.

Calculation of Company V’s excess management expenses for the purposes of group relief.

Management expenses (disbusrsed within year)£5,000
Sch A income£800
Profits & gains from non-trading loan relationships£3,000£3,800
Excess management expenses£1,200  

Company U's total profit, as reduced by other reliefs, is £1,300, calculated as follows.

Trading profits£1,000
Profits & gains from non-trading loan relationships£500
£1,500
Less charges paid£200
Total profits as reduced by other reliefs £1,300

So the group relief is limited to the smaller of £1,200 and £1,300, that is £1,200.

Company V's CT computation for the accounting period to 31 December 2002 is as follows.

Sch A income£800
Profits & gains from non-trading loan relationships£3,000
£3,800
Less management expenses£3,800
CT profits Nil

Company V's carry forward position as at 31 December 2002 is as follows.

Management expenses (including amounts brought forward from earlier periods)£5,500
Less allowed in computation£3,800
Surrendered as group relief£1,200£5,000
Excess management expenses available to carry forward£500

Company U's CT computation for the accounting period to 31 December 2002 is as follows.

Sch D, Case I income£1,000
Profits & gains from non-trading loan relationships£500
£1,500
Less charges£200
Less group relief claimed£1,200£1,400
CT profits£100