D2.231 Consortium Relief For Current Year Losses—Overlapping Accounting Periods

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Commentary

Corporate tax

Where the accounting periods of the claimant company and the surrendering company do not overlap, consortium relief is further restricted.

The amount of relief available is initially calculated as for group claims (D2.216), but then is further restricted by deeming a current year trading loss claim to have been made (see D2.230).

This restricted amount is applied¹:

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E5.607 Corporate members

I4.265 Lifetime transfers reported late

I7.504 Designation for the conditional exemption

C2.1020 Employment-related securities options and capital gains

E6.303A Domicile of origin

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