Group Relief

Group Relief

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Can the corporation tax losses of a company - created before it became a subsidiary - be group relieved once part of the group? The two subsidiaries carry on different trades, one profitable one breaking even with CT losses brought forward.

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By blok
16th Apr 2011 09:21

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No it can't. You must be part of the group at the time the losses were made to qualify. You may consider whether there is a possibility of management charges between the two companies. If there is this possibility, you can move some profits over and take advantage of the losses being bf. Needs to be commercial though.

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