The same types of losses and other amounts (
CTM80110) which can be surrendered on a
group claim to group relief can also be surrendered on a consortium
claim.
However there is a restriction on the amount of
trade losses that can be surrendered a company
owned by a consortium.
If the surrendering company has other profits in the
accounting period against which it could set off all or part of the
loss under ICTA88/S393A (1) (
CTM04500 onwards), then the amount of
trade loss available for surrender is restricted by the amount
which could be so set off, whether such a set off is claimed or
not.
See the example at
CTM80696.
ICTA88/S403ZA (4) provides that where both:
and
