»Ê¹ÚÌåÓýapp

CTA10/Ss138-142

This example shows the operation of CTA10/Ss138 to 142 (CTM80210 and CTM80215).

Company	Accounting period	Profit or Loss
A	12 months to 31 December 2011	Profit £72,000
B	12 months to 31 December 2011	Loss (£100,000)
C	6 months to 30 June 2011	Profit £5,000
D	12 months to 30 September 2011	Loss (£120,000)
E	12 months to 31 May 2012	Profit £160,000

A, B, C, and D are in a group relationship throughout. E joined the group on 1 June 2011.

C claims group relief from D.

A claims from D and then from B.

E claims from D and then from B.

C’s claim from D (no prior surrenders or claims)

»Ê¹ÚÌåÓýapp overlapping period (CTM80225) is the six months ended 30 June 2011.

D’s ‘unused part of the surrenderable amounts� is the same as its ‘surrenderable amount for the overlapping period� (CTM80230). This is because there have been no prior surrenders of D’s losses. It is:

6/12 x £120,00 = £60,000

C’s ‘unrelieved part of the claimant company’s available total profits is also the same as its ‘available total profits for the overlapping period� (CTM80235). This is because it has made no prior claims. It is:

6/6 x £5,000 = £5,000

»Ê¹ÚÌåÓýapp amount that can be surrendered/claimed is the smaller of these (CTM80215). It is £5,000.

A’s claim from D (prior surrender)

»Ê¹ÚÌåÓýapp overlapping period is nine months ended 30 September 2011.

D’s ‘surrenderable amount for the overlapping period� is:

9/12 x £120,000 = £90,000

D’s ‘unused part of the surrenderable amount� is this amount less the ‘amount of prior surrenders for the overlapping period�.

Following the steps in CTM80240:

Step 1

C’s prior claim from D involves part of D’s surrenderable amount for accounting period ended 30 September 2011

Step 2

C’s prior claim of £5,000 was for the overlapping period of six months ended 30 June 2011.

»Ê¹ÚÌåÓýapp common period of the overlapping periods in C’s claim and A’s claim is six months ended 30 June 2011.

»Ê¹ÚÌåÓýapp whole six month overlapping period for C’s prior claim is included in the common period, so the whole of the £5,000 is apportioned to that common period.

Step 3

»Ê¹ÚÌåÓýapp total, £5,000, is the ‘amount of any prior surrenders for the overlapping periodâ€�.

So D’s ‘unused part of the surrenderable amounts� is £90,000 less £5,000 which is £85,000.

A’s ‘unrelieved part of the claimant company’s available total profits� is the same as its ‘available total profits for the overlapping period�. This is because it has made no prior claims. It is:

9/12 x £72,000 = £54,000

»Ê¹ÚÌåÓýapp amount that can be surrendered/claimed is the smaller of £85,000 and £54,000, which is £54,000.

A’s claim from B (prior claim)

»Ê¹ÚÌåÓýapp overlapping period is 12 months ended 31 December 2011.

B’s ‘unused part of the surrenderable amounts� is the same as its ‘surrenderable amount for the overlapping period�. This is because there have been no prior surrenders of B’s losses. It is:

12/12 x £100,000 = £100,000

A’s ‘available total profits for the overlapping periodâ€� are £72,000. »Ê¹ÚÌåÓýapp ‘unrelieved part of the claimant company’s available total profitsâ€� is this amount less ‘the amount of previously claimed group relief for the overlapping periodâ€�.

Following the steps in CTM80245:

Step 1

A has claimed from D for the accounting period ended 31 December 2011.

Step 2

A’s prior claim from D of £54,000, was for the overlapping period of nine months ended 30 September 2011.

»Ê¹ÚÌåÓýapp common period of the overlapping periods for the claim from D and the claim from B is the nine months ended 30 September 2011.

»Ê¹ÚÌåÓýapp whole nine month overlapping period for the prior claim is included in the common period, so the whole of the £54,000 group relief given is apportioned to that common period.

Step 3

»Ê¹ÚÌåÓýapp total, £54,000, is the ‘amount of previously claimed group relief for the overlapping periodâ€�.

So A’s ‘unrelieved part of the claimant company’s available total profits� is £72,000 less £54,000 which is £18,000.

»Ê¹ÚÌåÓýapp amount that can be surrendered/claimed is the smaller of £100,000 and £18,000, which is £18,000.

E’s claim from D (prior surrenders)

»Ê¹ÚÌåÓýapp overlapping period is four months ended 30 September 2011.

D’s ‘surrenderable amount for the overlapping period� is:

4/12 x £120,000 = £40,000

D’s ‘unused part of the surrenderable amounts� is this amount less the ‘amount of prior surrenders for the overlapping period�.

Following the steps in CTM80240:

Step 1

C’s claim from D involves part of D’s surrenderable amount for accounting period ended 30 September 2011.

A’s claim from D involves part of D’s surrenderable amount for accounting period ended 30 September 2011.

Step 2

C’s prior claim of £5,000, was for the overlapping period of six months ended 30 June 2011.

»Ê¹ÚÌåÓýapp common period of the overlapping periods in C’s claim and E’s claim is the one month ended 30 June 2011.

»Ê¹ÚÌåÓýapp £5,000 is apportioned to that common period:

1/6 x £5,000 = £833

A’s prior claim of £54,000, was for the overlapping period of nine months ended 30 September 2011.

»Ê¹ÚÌåÓýapp common period of the overlapping periods in A’s claim and E’s claim is four months ended 30 September 2011.

»Ê¹ÚÌåÓýapp £54,000 is apportioned to that common period:

4/9 x £54,000 = £24,000

Step 3

»Ê¹ÚÌåÓýapp total £24,833 (£833 plus £24,000) is the ‘amount of prior surrenders for the overlapping periodâ€�.

So D’s ‘unused part of the surrenderable amounts� is £40,000 less £24,833 which is £15,167.

E’s ‘unrelieved part of the claimant company’s available total profits� is the same as its ‘available total profits for the overlapping period�. This is because it has made no prior claims. It is:

4/12 x £160,000 = £53,333

»Ê¹ÚÌåÓýapp amount that can be surrendered/claimed is the smaller of these: £15,167.

E’s claim from B (prior surrender and claim)

»Ê¹ÚÌåÓýapp overlapping period is seven months ended 31 December 2011.

B’s ‘surrenderable amount for the overlapping period� is

7/12 x £100,000 = £58,333

B’s ‘unused part of the surrenderable amounts� is this amount less the ‘amount of prior surrenders for the overlapping period�.

Following the steps in CTM80240:

Step 1

A’s claim from B involves part of B’s surrenderable amount for accounting period ended 31 December 2011.

Step 2

A’s prior claim from B of £18,000, was for the overlapping period of 12 months ended 31 December 2011.

»Ê¹ÚÌåÓýapp common period of the overlapping periods in A’s claim and E’s claim is seven months ended 31 December 2011.

»Ê¹ÚÌåÓýapp £18,000 is apportioned to that common period:

7/12 x £18,000 = £10,500

Step 3

£10,500 is the ‘amount of prior surrenders for the overlapping period�.

So B’s ‘unused part of the surrenderable amounts� is £58,333 less £10,500 which is £47,833.

E’s available total profits for the 12 month accounting period to 31 March 2012 are £160,000. Its available total profits for the overlapping period are:

7/12 x £160,000 = £93,333

»Ê¹ÚÌåÓýapp ‘unrelieved part of the claimant company’s available total profitsâ€� is this amount less ‘the amount of previously claimed group relief for the overlapping periodâ€�.

Following the steps in CTM80245:

Step 1

E has claimed from D for the accounting period ended 31 March 2012.

Step 2

E’s prior claim from D of £15,167, was for the overlapping period of four months ended 30 September 2011.

»Ê¹ÚÌåÓýapp common period of the overlapping periods in the claim from D and the claim from B is also four months ended 30 September 2011.

»Ê¹ÚÌåÓýapp whole four month overlapping period for the prior claim is included in the common period, so the whole of the £15,167 is apportioned to that common period.

Step 3

»Ê¹ÚÌåÓýapp total, £15,167, is the ‘amount of previously claimed group relief for the overlapping periodâ€�.

So E’s ‘unrelieved part of the claimant company’s available total profits� is £93,333 less £15,167 which is £78,166.

»Ê¹ÚÌåÓýapp amount that can be surrendered/claimed is the smaller of £47,833 and £78,166, which is £47,833.