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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Groups: group relief: surrendering company not UK resident: commencement

FA06/SCH1/PARA9

The rules apply to the accounting period of a claimant company beginning on or after 1 April 2006. In relation to the loss period, this begins on or after 1 April 2006 in which any loss or other amount arises to a non-resident company.

  • If the accounting period of a claimant company begins before 1 April 2006 and ends on or after that date, that accounting period is to be treated as two separate accounting periods, and the profits apportioned on a just and reasonable basis.
  • If the loss period of the non-resident company begins before 1 April 2006 and ends on or after that date, that loss period is to be treated as two separate loss periods, and the losses apportioned on a just and reasonable basis.

Meaning of ‘loss period’

In the above paragraphs a reference to a ‘loss period’ is to be read as a reference to the period defined by the rules of the relevant European Economic Area (EEA) territory for which the EEA tax loss is computed. As these terms are likely to change depending on the territory, the term ‘loss period’ is used in the legislation.This could be a period of account, a tax return period or some other period where these are coincident.