Can a trading loss from a UK resident subsidiary be transfered and set off against rental income surplus of the UK resident holding Company for Corporation Tax purposes?
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No
Group relief just wouldn't work if that were the case.
Essentially, you (the surrenderor) can put your trade losses, property business losses and non-trade loan relationship deficits in a big bucket, and give the bucket (surrender the losses) to another member of a 75% group.
The recipient of the losses (the claimant) can then take all the losses out of the bucket in one big indistinguishable chunk and set them against their total profits (relieve the losses).
There are restrictions on the amount that can be surrender and relieved where year-ends aren't coterminous (although generally they will be) and where both surrenderor and claimant haven't been members of the group throughout a period.
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no there isn't. the rules are quite relaxed.
you need to ensure that the periods are co-terminus and the claimant company should claim any reliefs in priority to the group relief claim.