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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: group relief

Group relief

A company in this regime will normally have a small profit or exceptionally a nil result. It will not have tax losses. It is possible that some companies within the same group for the purposes of CTA10/Part 5 might be within the securitisation regime and others within the normal CT rules. To avoid the possibility that losses could be claimed by securitisation companies, Regulation 17 provides that a securitisation company is not treated as a member of any group or consortium.

Regulation 17 does not apply if the company has been excluded from the securitisation regime by virtue of failing the payments condition or unallowable purposes test (CFM72570). In such a case the company will still be a securitisation company for the purposes of the regulations, except for Regulation 14. It will be taxed on its accounting profit in the usual way and can claim and surrender group relief in the usual way.