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HMRC internal manual

Company Taxation Manual

Groups: group relief: order of relief for amounts which can be surrendered


The legislation provides an order of surrender for “relevant amounts” (CTM80142).  The amount surrendered is treated as (CTA10/S105(4)):

a. first, charitable donations within CTA10/S99(1)(d),

b. second, UK property business losses within CTA10/S99(1)(e),

c. third, management expenses within CTA10/S99(1)(f), and

d. fourth, non-trading losses on intangible assets within CTA10/S99(1)(g).