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HMRC internal manual

Company Taxation Manual

Corporation Tax self assessment (CTSA): group relief - general: withdrawal of consent

When a surrendering company wishes to change the amount of group relief it has surrendered, it cannot amend any notice of consent it has previously given. Instead, it must withdraw the earlier notices and replace them with new ones (FA98/SCH18/PARA71 (2)).

FA98/SCH18/PARA71 (3) requires that the withdrawal of consent be made by notice to the same Tax office to which it was originally given. In practice, where responsibility for the tax affairs of the company has been transferred from one Tax office to another, the notice should be given to the new office.

To be valid, a notice from the claimant company signifying its consent to the withdrawal must accompany a notice of withdrawal, (FA98/SCH18/PARA71 (4)). The only exception to this is when the consent is withdrawn under FA98/SCH18/PARA75 because of a reduction in the amount available for surrender (see CTM97070).

The claimant company must amend its return to reflect the withdrawal of consent (FA98/SCH18/PARA71 (5)).