Company in Liquidation - HMRC's Rights

Client company has been put into liquidation.

Liquidator has prepared a statement of affairs showing a deficit.

Within the unsecured creditors are paye of £15k and VAT of £6k.

A large trading loss has been made in the final period of trading, which we are considering making a loss relief claim for.

The corporation tax relief due will be circa £17.5k. Will HMRC have the right to transfer this against the outstanding paye/vat liability or will they be required to repay it and then receive their proportion of the dividend paid out to creditors with this refund?

If the former, there seems little point in putting in the claim as their will be no other assets to claim our fees against?