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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Groups: group relief: meaning of non-trading losses on intangible fixed assets

CTA10/S99(1)(g),  CTA10/S104, Part 8 of CTA09, CTA10/S105

Non-trading losses on intangible fixed assets can be surrendered and claimed as group relief (CTM80105 and CIRD13550).  The loss that is available for relief is one calculated under Part 8 of CTA09 (see CIRD13550).

Non-trading losses on intangible fixed assets is a ‘relevant amount’ for the group relief provisions, so can only be surrendered to the extent that the total of the surrendering company’s relevant amounts exceeds the ‘profit-related threshold’ (or ‘gross profit’ in surrendering periods ended before 20 March 2013; see CTA10/S105, CTM80142).  This is the case regardless of whether the surrendering company uses any of the relevant amounts against its own profits.

The calculation will need to take into account the prescribed order of surrender of relevant amounts (see CTM80143).

It does not include amounts brought forward from an earlier accounting period under CTA09/S753(3).