In order to quantify the loss eligible for relief, the
foreign loss is to be recomputed in accordance with UK
To enable the recomputation to be carried out, the extended rules require assumptions to be made about the surrendering company.
In the following paragraphs a reference to a ‘loss period’ is to be read as a reference to the period defined by the rules of the relevant European Economic Area (EEA) territory for which the EEA tax loss is computed. This could be a period of account, a tax return period or some other period where these are coincident.
It is assumed that the company:
Any trade carried on by a company wholly outside the UK would
fall to be assessed, for UK corporation tax purposes, under Case V
of Schedule D. Any losses arising from such a trade would therefore
be Case V losses and unavailable for surrender by way of group
It is therefore assumed that: