Not utilising a surrendered loss

Carrying forward/backward surrendered losses that are not utilised

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Dear members,

I was reading about the group relief rules (i'm a Dutch tax student) and read the following: "Where a loss is surrendered to a group company, it must be utilised within that chargeable period and cannot be further surrendered to another group company, carried back against prior period profits or withheld and carried forward for use against furure losses". I was wondering from which article(s) in the CTA 2010 I can conclude that the above is right? The text I quoted does not contain any sources. 

Thanks in advance.

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By Tax Dragon
11th Apr 2019 21:31

You'll need to read around it, but include s138 in what you read.

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Replying to Tax Dragon:
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By Robvdw
12th Apr 2019 10:50

I think I found the answer now: S138(a) jo S139(1) and (2). Thanks alot!

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Replying to Robvdw:
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By Tax Dragon
12th Apr 2019 17:29

I'll be honest with you: I don't really know what "Where a loss is surrendered to a group company, it must be utilised within that chargeable period and cannot be further surrendered to another group company, carried back against prior period profits or withheld and carried forward for use against furure losses" means. So I'm not sure that s138(a) and s139(1) and (2) are what you're looking for. But they (along with s138(b), s140 and other sections around there) tell you the actual rules. So that's better, right?

On a personal note, it might help your future interactions with us Brits, if you avoid an excess of exclamation marks. Some of us (not me, obviously) are a little bit weird and think that they can imply some form of sarcasm - a particularly English trait, I'm afraid. "Thanks a lot!" read sarcastically could cause some of my countryfolk some unnecessary offence.

You'll learn our quirks if you're based here. They can be even more bizarre and complex than our tax system.

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