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HMRC internal manual

Company Taxation Manual

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).