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Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.2 Group relief for current year and carried forward losses /Group relief—restrictions on losses surrenderable by overseas entities / D2.264 Group relief—dual resident investing companies
Commentary

D2.264 Group relief—dual resident investing companies

Corporate tax

Specific provisions prevent a company surrendering losses by way of group relief, consortium relief or group relief for carried forward losses if during the period in which the loss is incurred it is a dual resident investing company1.

The determination of the residence of a company is described in D4.103. Where different countries have different tests for determining whether a company is resident it is possible for a company to be resident in

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