Assume there are no differences between UK and foreign measures
of income and expenditure.
Foreign computation
| Foreign trading loss | (£200) |
| Foreign non-trade interest | (£100) |
| Other foreign income | £100 |
| Unrelievable foreign loss | (£200) |
UK recomputation
| UK trading loss | (£200) |
| Non-trading loan relationship deficit | (£100) |
| UK measure of losses available for group relief | (£300) |
| Other income | £100 |
The company was dissolved on the last day of the accounting
period, and apart from the sideways set-off of £100 of the
loss, there is no other possibility whatsoever of relief for the
loss in any way.
A UK company could choose to surrender all £300 as group
relief, leaving £100 of other income within the charge to tax,
as the company does not have to use trading losses and non trading
loan relationship deficits against its other profits first (
CTM80110).
However a foreign loss or other amount only meets the
qualifying loss condition to the extent that relief cannot be given
for any period. In the European Economic Area territory £100
of either the foreign trading loss or the foreign non-trade
interest has been relieved against the other foreign income. This
amount does not meet the qualifying loss condition and therefore
the amount available for relief in the UK is £200.
