CTM80445 - Groups: group relief: example - surrender of excess management expenses

In the year ended 31 December 2012 Company U is a 75% per cent subsidiary of Company V, which is a group holding company. Both companies make up their accounts to 31 December. »Ê¹ÚÌåÓýapp accounts and computations of the companies for the 12 months accounting period to 31 December 2012 show the following.

Company V £
Management expenses disbursed within year (CTA09/S1219 (1)) (£5,000)
Management expenses brought forward (CTA09/S1223) (£500)
UK property business income £800
Profits & gains from non-trading loan relationships £3,000
Company U £
Trading profits £1,000
Profits & gains from non-trading loan relationships £500
Qualifying charitable donations paid (£200)

Company U claims group relief from Company V, with the consent of Company V. Group relief is limited to the smaller of:

  • Company V’s excess of management expenses (the only ‘relevant amountsâ€�) over the ‘gross profitsâ€� for the accounting period (CTM80142 â€� note this is a period ending before 20 March 2013), and
  • Company U’s ‘available total profitsâ€� as reduced by qualifying charitable donations paid (CTM80400).

Company V’s excess of management expenses over the total profits for the accounting period is £1,200. Under CTA10/S103 for group relief purposes management expenses do not include amounts carried forward from earlier periods. So, in this case, the £500 management expenses brought forward from the previous accounting period are disregarded.

Calculation of Company V’s excess management expenses for the purposes of group relief.

Management expenses (disbursed within year): £5,000

UK property business income: £800

Profits & gains from non-trading loan relationships: £3,000

Excess management expenses: £1,200

Company U’s ‘available total profits�, as reduced by other reliefs, is £1,300, calculated as follows.

Trading profits: £1,000

Profits & gains from non-trading loan relationships: £500

Total profits: £1,500

Less qualifying charitable donations paid: (£200)

Total profits as reduced by other reliefs: £1,300

So the group relief is limited to the smaller of £1,200 and £1,300, that is £1,200.

Company V’s CT computation for the accounting period to 31 December 2012 is as follows.

UK property business income: £800

Profits & gains from non-trading loan relationships: £3,000

Total Profits: £3,800

Less management expenses: (£3,800)

CT prodits: Nil

Company V’s carry forward position as at 31 December 2012 is as follows.

Management expenses (including amounts brought forward from earlier periods): £5,500

Less allowed in computation: (£3,800)

Surrendered as group relief: (£1,200)

Total management expenses utilised: (£5,000)

Excess management expenses available to carry forward: £500

Company U’s CT computation for the accounting period to 31 December 2012 is as follows.

Trading income: £1,000

Profits & gains from non-trading loan relationships: £500

Total Profits: £1,500

Less qualifying charitable donations: (£200)

Less group relief claimed: (£1,200)

Total reliefs claimed : (£1,400)

CT profit: £100