Priority of group and consortium relief
Where a company is owned by consortium companies but is also a member of a group, the basic premise is that group relief will take priority over consortium relief1.
Example 1
C Ltd is owned by A Ltd (75%) and B Ltd (25%).
As A Ltd owns 75% of C Ltd, there is a group of A Ltd and C Ltd, so group relief will apply. This will give A Ltd entitlement to all of C Ltd's losses. B Ltd will get nothing because group relief takes priority.
If the ownership of C Ltd was 74% (A Ltd) and 26% (B Ltd) this would be a consortium and consortium relief would apply, giving A Ltd entitlement to 74% of C Ltd's losses and B Ltd entitlement to 26% of C Ltd's loss; the additional 1% would make a great deal of difference to B Ltd.
Surrendering company is both owned by a consortium and is a member of a group
In some circumstances
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Web page updated on 17 Mar 2025 16:20