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CTA10/S138

»Ê¹ÚÌåÓýapp following guidance sets out how CTA10/S138 operates with Ss139 and 140 to limit group relief in various circumstances.

Where there are a number of claims or surrenders made by companies in a group, and:

• some accounting periods do not coincide, or
• not all of the claimant or surrendering companies are members of the group throughout,

there are detailed rules for calculating the amount of relief. »Ê¹ÚÌåÓýapp basic approach is to take each claim in turn, establish the “overlapping periodâ€� and then:

Step 1 –calculate the surrenderable amount

CTA10/S139(1) requires you to calculate the “unused part of the surrenderable amounts� by:

• working out the surrenderable amount for the overlapping period (CTM80230),
• reducing this amount by the amount of any prior surrenders attributable to the overlapping period (CTM80240).

Step 2 –calculate the claimable amount

CTA10/S140(1) requires you to calculate the “unrelieved part of the claimant company’s available total profits� by:

• working out the claimant company’s available total profits for the overlapping period (CTM80235), and,

• reducing this amount by the amount of any previously claimed group relief attributable to the overlapping period (CTM80245).

»Ê¹ÚÌåÓýapp amount of the group relief claim must not exceed the smaller of the results of Step 1 and Step 2,

• the unused part of the surrenderable amounts, and
• the unrelieved part of the claimant company’s total profits.

»Ê¹ÚÌåÓýappre is an example at CTM80255.