A Ltd is a full subsidiary of B Ltd.
A is taken into administration and liquidated resulting in capital losses. B wishes to utilise these losses via group relief.
Just had a client ask me if I can move some of the 2012/13 income to 2013/14 financial year to reduce their tax bill for 2012/13 as they are expecting a loss in 2013/14.
The First Tier Tax Tribunal recently heard the case of Ghelanis Superstore and Cash and Carry Ltd v HMRC (TC03251).
I have a client, Company A, who in Nov-13 purchased 100% of the shares in Company B. Company B has losses for the financial year ended Apr-13 but not yet completed it's tax return.
Firstly, I am in the process of talking to an accountant about these issues, but thought I'd put them in front of you too.
Been on HMRC website and difficult to get a definitive answer on this: