RPDT20420 - The charge to RPDT: reliefs: RPDT group relief - section 41 and part 2 of schedule 7 Finance Act 2022

Group relief for RPD losses is provided for by FA22/Sch7/Part2.  This is a stand-alone form of group relief that applies for RPDT but the rules for computing the surrenderable amount for Corporation Tax group relief apply as do the administrative rules. 

Where a group has entered into the “joint amended return” arrangements provided for in FA98/Sch18/Para77 then RPDT amounts may be included in that return.

Note that the meaning of a group for this purpose is the same as that for Corporation Tax group relief and is not the same as the slightly wider meaning of group for other purposes of RPDT.

Guidance on group relief for Corporation Tax generally can be found at CTM80100 onwards, the content applicable to surrender of trading losses applies to the surrender of RPDT group relief.

The general Corporation Tax rules for consortium relief do not apply to RPDT, instead a loss of a joint venture may be attributed to its member where an election is made, as explained at RPDT20300.

RPDT1100 contains a general introduction to RPDT and a list of abbreviations used.