Group relief

What is group relief?

Group relief is a mechanism that allows members of a corporation tax loss relief group (for which, see below) to share the benefit of certain corporation tax losses. One member of the group can surrender these losses to another member of the group, which can deduct the loss from its total profits, thus reducing the amount of corporation tax payable.

Group relief allows one group company to surrender its current year losses and/or carried-forward losses to other group members.

What makes a loss relief group?

A corporation tax loss relief group is formed if:

1. •

   company B is a 75% subsidiary of company A, or

2. •

   company A and company B are both 75% subsidiaries of company C

Company B is a 75% subsidiary of company A if:

1. •

   A beneficially owns, directly or indirectly, 75% of the ordinary share capital of B

2. •

   A is beneficially entitled to 75% of the profits available for distribution to equity holders of B (the profits test), and

3. •

   A would be beneficially entitled to 75% of the assets available for distribution to equity