What is the purpose of section 129 of the Corporation Tax Act 2010?

Section 129 acts as a roadmap to the chapter on group relief claims. It does not contain substantive rules but signposts key provisions that follow, explaining how claims are made, how relief is given as a deduction from total profits, and the limitations that apply to group relief.

How is group relief given under the Corporation Tax Act 2010?

Group relief operates as a deduction from the claimant company's total profits, as explained in section 137. A company within a group or consortium can surrender certain tax losses or other amounts to another company, which then uses them to reduce its own corporation tax liability.

What limitations apply to group relief claims under sections 138 to 149?

Sections 138 to 142 establish a general cap on group relief available on any claim, applying universally regardless of the group relationship type. Sections 143 to 149 impose additional specific limitations where the claim is made under consortium conditions 1, 2 or 3, reflecting shared ownership arrangements.

Can a company surrender its full trading loss as group relief to another group member?

A company can surrender up to its full trading loss to another group member, which then claims group relief to reduce its taxable total profits. However, the actual relief given is subject to the general limitations in sections 138 to 142, and if consortium arrangements apply, further limitations in sections 143 to 149.

Corporation Tax Act 2010 section 129

Overview of Chapter

Section 129 provides an overview of the chapter dealing with claims for group relief, explaining how claims are made, how relief is given, and the limitations that apply.

The chapter covers how a company may claim group relief, how that relief is given, and the limits on the amount of relief available.
Sections 130 to 134 deal with claims relating to surrenderable amounts, while section 137 explains how group relief is actually given as a deduction from total profits.
Sections 138 to 142 set out a general limitation on the amount of group relief that can be given on any claim.
Sections 143 to 149 impose additional limitations on claims made under consortium arrangements (consortium conditions 1, 2 or 3).

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