Group relief Definition

GLOSSARY

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What does Group relief mean?

This relief enables one company (the surrendering company) to surrender its current trading losses, capital allowances, non-trading deficits on loan relationships, excess management expenses, excess property business losses, excess non-trading losses on intangible fixed assets and excess charges on income, to another company (the claimant company), provided that both companies are in the same group throughout the relevant and respective accounting period(s).

The claim for group relief must be made in the claimant company's tax return (but it can be made by amendment to the original return). For the purposes of group relief, two companies are members of the same group if one is a 75% subsidiary of the other, or both are 75% subsidiaries of a third company. Group relief may also be claimed by members of a consortium in respect of losses and other debit items incurred by a company owned by the consortium.

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View the related checklists about Group relief

GAAR guidance: examples of non-abusive transactions—checklist

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Group relief—loss relief group

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Group relief—types of losses that can be surrendered

This Practice Note considers the types of current year and carried-forward losses that can be surrendered by way of group relief.A company can surrender the following current year losses by way of group relief:•a trading loss•a capital allowance excess•a non-trading loan relationship deficit•qualifying charitable donations•a UK property business loss•management expenses•a non-trading intangible fixed asset loss, and•amounts allowable as qualifying expenditure on grassroots sports (from 1 April 2017)A company can also surrender the following carried-forward losses (provided they were incurred after 1 April 2017) by way of group relief:•a carried-forward trade loss•a carried-forward non-trading loan relationship deficit•a carried forward UK property business loss•carried-forward management expenses, and•a carried forward non-trading intangible fixed asset lossThese amounts, further defined and explained in this Practice Note, are only available for surrender by way of group relief if they would be eligible for corporation tax relief for the company surrendering the losses under another provision, ie if the loss would not be deductible in the company that incurs the loss (assuming that company had profits to...

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Dive into our 17 Precedents related to Group relief

Is there any guidance as to the appropriateness of defining ‘Control’ as either (a) in accordance with section 1124 of the Corporation Tax Act 2010, or as (b) the beneficial ownership of more than 50% of the issued share capital of a company or the legal power to direct or cause the direction of the general management of the company?

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When I have requested HMRC’s Stamp Office to adjudicate and stamp the enclosed stock transfer forms, is it usual for HMRC only to impress a monetary stamp on the stock transfer forms and not to include an adjudication stamp?

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See the 29 Q&As about Group relief

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