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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 - periods straddling 2 July 1997

F2A97/SCH7/PARA9

The rules in ICTA88/S403A (CTM80210 and CTM80215) do not apply to accounting periods that straddle 2 July 1997 if the overlapping period (CTM80225) is entirely before that date. Instead the old rules in ICTA88/S408 and ICTA88/S409 apply.

If the overlapping period straddles 2 July 1997, calculate the relief as follows.

Step 1

Work out the amount of relief that would have been due under the old rules in Section 408 (accounting periods do not coincide) or as the case may be Section 409 (companies joining or leaving group).

Step 2

Work out the amount of relief that would have been due under the old rules in Section 408 or Section 409 on the assumption that:

  • For Section 408 the common period numerator A is the period from 2 July 1997 to the end of the overlapping period.
  • For Section 409 the assumed notional accounting period is the period from 2 July 1997 to the end of the overlapping period.

Step 3

Work out the amount of the relief that would be due under the rules in Section 403A on the assumption that the overlapping period begins on 2 July 1997.

Step 4

Work out the amount if any by which the result from Step 2 exceeds the result from Step 3.

Step 5

Subtract the result of Step 4 from the result of Step 1.

The result of Step 5 is the amount of group relief allowable on the claim.