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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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Groups: group relief: non coinciding accounting periods or group relationships - overlapping period

CTA10/S142

Where:

  • a claimant’s and surrendering company’s accounting periods do not coincide, or
  • the claimant and surrendering company are not members of the same group (CTM80150) throughout an accounting period,

then for the purposes of CTA10/S138 CTM80215) the ‘overlapping period’ is the period common to the accounting periods of the claimant company and surrendering company or, as the case may be, the period for which the companies were members of the same group.

In addition, periods for which the general group relief conditions are not met are excluded from the overlapping period.