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Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.2 Group relief for current year and carried forward losses /Group relief—administration / D2.243 Payment for group relief—current year and carried forward losses
Commentary

D2.243 Payment for group relief—current year and carried forward losses

Corporate tax

It is not necessary for the claimant company to make any payment to the surrendering company for the benefit of the losses, etc. Nevertheless, for commercial reasons it is often appropriate that some payment be made (for example it is normally appropriate for a payment to be made where a minority outside shareholding is involved, or where consortium relief is involved and some members are unable to make claims).

A payment for group relief (for current year or brought forward losses) is not taken into account in computing profits or losses of either the claimant or the

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