CTM80100 - Groups: group relief: contents

This chapter applies for accounting periods ending on or after 1 April 1998

CTM80105Outline
CTM80110Reliefs which may be claimed
CTM80115Trading losses
CTM80120Excess capital allowances
CTM80125Non-trading loan relationships deficits
CTM80130Excess charges
CTM80135Schedule A losses
CTM80136Schedule A losses: transitional provisions
CTM80140Excess management expenses
CTM80141Non-trading losses on intangible fixed assets
CTM80142Excess of charges etc. over other profits
CTM80143Order of relief for amounts which can be surrendered
CTM80145Claims for relief
CTM80150Companies affected
CTM80155Qualifying tests
CTM80160Qualifying tests: application of
CTM80165Arrangements: transfer of company to another group
CTM80170Control
CTM80175Arrangements disqualifying relief
CTM80180Definitions of third company and successor
CTM80185Enabling arrangements
CTM80190Direct arrangements
CTM80195Date of arrangements
CTM80200Information about arrangements
CTM80205SP3/93 and ESCC10
CTM80210Non coinciding accounting periods or group relationships
CTM80215Non coinciding accounting periods or group relationships: multiple claims
CTM80220Non coinciding accounting periods or group relationships: order of dealing with claims
CTM80225Non coinciding accounting periods or group relationships: overlapping period
CTM80230Overlapping period: surrenderable amount and claimant’s profits
CTM80235Overlapping period: unused part of surrenderable amount and unrelieved part of claimant’s profits
CTM80240Overlapping period: amount of any prior surrenders attributable thereto
CTM80245Overlapping period: amount of any previous claims attributable thereto
CTM80250Non coinciding accounting periods or group relationships: periods straddling 2 July 1997
CTM80255Non coinciding accounting periods or group relationships: example
CTM80260Apportionment of profit or loss
CTM80265Apportionment of profit or loss: management accounts
CTM80270Apportionment of profit or loss: apportioned amount not to exceed total loss
CTM80300The international aspect: overview
CTM80305The international aspect: permanent establishments
CTM80310UK permanent establishment of non-resident company
CTM80315UK permanent establishment of non-resident company: tax relief in a foreign jurisdiction
CTM80320UK permanent establishment of non-resident company: tax relief in a foreign jurisdiction: meaning
CTM80325UK permanent establishment of non-resident company: tax relief in a foreign jurisdiction: credit and exemption countries
CTM80330Meaning of non-UK profits
CTM80335Meaning of foreign tax
CTM80340UK permanent establishment of non-resident company: losses exempted by double taxation agreements
CTM80345UK permanent establishment of non-resident company: amounts which can be surrendered
CTM80350Overseas permanent establishment of UK resident company
CTM80355Overseas permanent establishment of UK resident company: meaning of attributable to overseas permanent establishment
CTM80360Overseas permanent establishment of UK resident company: meaning of tax relief in a foreign jurisdiction
CTM80365Overseas permanent establishment of UK resident company: foreign ‘tie-breaker’ rules
CTM80370The international aspect: accounting period straddling 1 April 2000
CTM80400Limit of relief
CTM80405Exclusion of double allowances
CTM80410Cases of difficulty
CTM80415Avoidance
CTM80435Example: surrender of trading losses
CTM80440Example: surrender of excess capital allowances
CTM80445Example: surrender of excess management expenses
CTM80450Example: surrender of excess charges