CTM82545 - Corporation Tax: Group relief for carried-forward losses: Consortia: Overlapping period

CTA10/S188DG, CTA10/S188EH

One of the conditions for a claim for group relief for carried-forward losses is that there must be an overlapping period. This is the period that is common to the claim period and the surrender period and during which one of the consortium conditions is met (CTA10/S188DG(1), CTA10/S188EH(1)). The amount of group relief for carried-forward losses that can be claimed or surrendered is arrived at by reference to the overlapping period.

If during any part of the overlapping period the relevant consortium condition is not met, that part is excluded from the overlapping period (CTA10/S188DG(2), CTA10/S188EH(2)).

Claim period

This is the accounting period of the claimant company for which it claims group relief for carried-forward losses (CTA10/S188CB(2), CTA10/S188CC(3)).

Surrender period

This is the accounting period of the surrendering company to which the losses and other amounts have been carried forward (CTA10/S188BB(7)).