The extension to group relief can be claimed by:
Where the surrendering company is a 75% subsidiary of more than
one UK resident company, then a loss may be claimed under the new
rules by any of those companies (or by any other UK resident 75%
subsidiary of those companies).
The definition of a 75% subsidiary is the same as that used
for the existing group relief rules which is in ICTA88/S838 (1).
There is detailed guidance at
CTM80510.
A foreign 75% subsidiary of a qualifying claimant company with a foreign tax loss ( CTM81520) where that subsidiary is:
Losses attributable to a UK permanent establishment of the surrendering company are excluded from the new rules. The existing group relief rules continue to apply to such losses, ( CTM80310).
