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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
Updated
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Loan relationships: non-trading deficits: group relief

Group and consortium relief claims

A group or consortium relief claim falls under the general rules for group and consortium relief in ICTA88/S402 - 411, with details of how to make a claim in FA98/SCH18/PARA66 to 76 - see CTM97600.

Restriction of consortium relief

In some circumstances there is a restriction to debits for bad debts, or impairment losses for accounting periods starting on or after 1 January 2005, where a company has had consortium relief. There may also be a restriction on the amount of the group relief that a company can claim if it has already had bad debt debits, or impairment loss, in earlier years from a loan relationship with the consortium member surrendering group relief. There are details at CFM34000.

Group relief

There’s no similar restriction on group relief arising in a group situation, as group companies cannot have bad debt relief, or impairment losses for accounting periods starting on or after 1 January 2005, because they are connected (CFM35000).