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HMRC internal manual

Company Taxation Manual

Groups: group relief: overseas permanent establishment of UK resident company - meaning of attributable to overseas permanent establishment


For general guidance on the restriction of losses and other amounts that can be surrendered as group relief by a UK resident company that trades through an overseas permanent establishment see CTM80350.

For the purposes of the restriction, a loss, etc is attributable to the overseas permanent establishment insofar as:

  • looking solely at the activities of the permanent establishment, it would be surrenderable as group relief,
  • by following the principles for determining what loss or other amount could be surrendered by a non-resident company carrying on a trade in the UK through a UK permanent establishment.