Corporation Tax Act 2010 section 102

Meaning of "UK property business loss"

Section 102 defines what counts as a "UK property business loss" for the purposes of surrendering losses as group relief.

  • A UK property business loss is a loss made in a UK property business during the surrender period
  • Losses brought forward from earlier periods and treated as made in the surrender period under loss relief rules are excluded
  • Only current-year UK property business losses qualify for surrender as group relief
  • Non-commercial property losses cannot be surrendered as group relief because they are not eligible for corporation tax relief outside the group relief rules

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