Corporation Tax Act 2010 section 137

Deduction from total profits

Section 137 explains how group relief is given to the claimant company by way of a deduction from its total profits, and sets out the ordering rules and limitations that apply to that deduction.

• Group relief is given as a deduction from the claimant company's total profits for the claim period, equal to all or part of the surrendering company's surrenderable amounts for the surrender period.
• The deduction is subject to several limitations, including caps that apply to all group relief claims, additional caps for consortium-based claims, restrictions for losses from limited partnerships or limited liability partnerships, and rules for oil activities.
• Group relief is deducted after most other reliefs at Step 2 of the corporation tax calculation, but before certain carry-back reliefs and before reliefs subject to the carried-forward loss restriction rules in Part 7ZA — and the company is assumed to have claimed all available current-period trade loss relief and excess capital allowances relief.
• Corporation tax relief cannot be given more than once for the same amount, whether by combining group relief with another relief given to the surrendering company or by giving group relief twice.