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HMRC internal manual

Property Income Manual

Losses: group relief (CT)


The rules in ICTA88/S403 that quantify the losses and other amounts which can be surrendered as group relief, were rewritten in FA98. Adding extra rules dealing with Schedule A losses would have made them even more difficult to understand.

Although the rewritten rules deal with all the amounts that can be surrendered as group relief, and not just Schedule A losses, the effect of the rules for amounts other than Schedule A losses has not changed. The detailed guidance is at CTM80135.

ICTA88/S403ZD (3) defines a Schedule A loss as a loss incurred in a Schedule A business carried on by the surrendering company in the accounting period. It also prevents:

  • Schedule A losses carried forward from earlier accounting periods,


  • losses incurred in a Schedule A business not carried on with a view to making a commercial profit

from being treated as a Schedule A loss for this purpose.