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HMRC internal manual

Company Taxation Manual

Groups: group relief: cases of difficulty


  • you have any difficulty in applying the group relief rules, or
  • there is evidence of manipulation which cannot be countered by the rules in CTA10/S154 (CTM80165) or CTA10/S151(4) and Chapter 6 of Part 5 of CTA10 (CTM80155)

Then you should submit such cases to a CT Technical Specialist.