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HMRC internal manual

Property Income Manual

Losses for CT: group relief


Surrendering property business losses as group relief

CTA09/S99 deals with all the amounts that can be surrendered as group relief, and not just property business losses, the effect of the rules for amounts other than property business losses has not changed. 

CTA10/S102 defines a property loss as a loss incurred in a UK property business carried on by the surrendering company in the accounting period.

Property business losses carried forward from earlier accounting periods (CTA10/S102) and non-commercial property losses (CTA10/S64) are not included for the purpose of group relief.

Detailed guidance is available at: 

  • General overview of group relief: CTM80105

  • What can be surrendered as group relief: CTM80110

  • The meaning of a UK property business loss for group relief purposes: CTM80135

  • The order of surrender for “relevant amounts”: CTM80143

  • How to make a claim for group relief: CTM80145

Reform of Corporation Tax loss relief

As of 1 April 2017, the relief available for trading losses carried forward has changed. Three sets of guidance have been published in draft: tranche 1, tranche 2 and draft guidance on commencement provisions.