CFM35650 - Loan relationships: consortia companies and impairment: amount of restriction: example
Example: restriction: net consortium debit
Porwin Ltd is a consortium company owned
- 50% by Ulla (South) Ltd
- 50% by Rewdon Manufacturing Ltd.
Ulla group
Ulla (South) Ltd and Ulla (North) Ltd are members of the Ulla group of companies.
Year 1
Ulla (South) Ltd lends Porwin Ltd £30,000. Ulla (North) lends it £60,000. Ulla plc lends it £100,000 and writes this down by £50,000. This is an impairment loss.
The net consortium debit is £50,000.
Year 2
Ulla (South) Ltd writes down £20,000 of its loan. Ulla (North) Ltd writes down £40,000, while Ulla plc reduces its provision for impairment by £15,000.
The net consortium debit for the Ulla group in Year 2 is
Written off | £60,000 |
---|---|
Impairment reduction credit | £15,000 |
Net consortium debit | £45,000 |
Rewdon group
Rewdon Manufacturing Ltd is a member of the Rewdon group.
Year 1
In this year, Rewdon Manufacturing Ltd made a loan of £100,000 to Porwin Ltd. Rewdon Manufacturing Ltd has written it down to £40,000, charging an impairment debit of £60,000. No other member of the Rewdon group has made a loan to Porwin Ltd.
The net consortium debit for the group for this year is £60,000.
Year 2
There were no impairment losses or reversals.
The amount of the group relief restriction
The amount of restriction to impairment debit and release debit {#}hinges on the group relief that each consortium member, or members of its group, claims from the consortium company.
So if, in Year 1, Porwin Ltd (owned 50% by Ulla (South) Ltd and 50% by Rewdon Manufacturing Ltd) has losses of £102,000 available to surrender, the maximum amount of group relief that the Ulla group can claim, under CTA10/S143, is the lesser of
- 50% of the loss available to surrender (£51,000)
- the amount of total profits as reduced by any other relief.
The same rules apply to the Rewdon group.