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HMRC internal manual

Company Taxation Manual

Groups: group relief: Schedule A losses - transitional provisions

ICTA88/S403 (1) and (3), ICTA88/S403ZD (3), FA98/SCH5/PARA67, FA98/SCH5/PARA72

Schedule A losses brought forward from an earlier period cannot be added to the Sch A losses of an accounting period and surrendered as group relief (CTM80135).

An exception to this is where, as at 1 April 1998, there are unrelieved Schedule A expenses (PIM4620). For the purposes of computing Schedule A profits or losses such expenses are treated as having been incurred on 1 April 1998. So they can be surrendered as group relief for the accounting period into which 1 April 1998 falls.

Note that this exception does not apply to Case VI losses at 1 April 1998 brought forward into Schedule A by FA98/SCH5/PARA72.