Groups: group relief: meaning of deficits on non-trading loan relationships
CTA10/S99(1)(c), Chapter 16 of Part 5 of CTA09
Deficits on non-trading loan relationships can be surrendered and claimed as group relief (see CTM80105 for group relief, and CFM32030 for an overview of non-trading loan relationships, including the use of deficits on non-trading loan relationships).
The surrendering company does not have to use the deficit against its other income in priority to surrendering some or all of it as group relief to a fellow group member. Nor is the amount that can be surrendered restricted to the excess over other profits for the accounting period of surrender - CTA10/S S99(2)-(3).