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HMRC internal manual

Corporate Finance Manual

Loan relationships: non-trading deficits: claims for set-off against profits of the same or earlier periods

General conditions for claims

No claim can be made in respect of a deficit that is surrendered as group relief.

No claim can be made by a company that is a charity.

Time limits

Companies are entitled to make a group relief claim at any time up to the first anniversary of the filing date for the accounting period of the claim (CTM97045).

Claims under CTA09/S459(1) must be made within 2 years of the end of the accounting period in which the deficit period arose (CTA09/S460), although an officer of Revenue and Customs may extend the time limit. Requests to extend the time limit in CTA09/S460 should be referred to CT&VAT (Trading and Property Income Team).

No double counting

While a company can claim in different ways for different parts of the deficit, CTA09/S460(2) and (3) ensures that it can’t claim more than once for the same part. For example, if a company has a deficit of £7,000, it could

  • surrender £4,000 as group relief
  • make a claim to set £1,000 against profits of the current year
  • make a claim to carry back £500
  • carry forward the balance, £1,500

or any combination of these reliefs up to the amount of the deficit.