Corporation Tax Act 2010 section 138

Limitation on amount of group relief applying to all claims

Section 138 sets out the overall cap on the amount of group relief that can be given on any particular claim.

• Every group relief claim is subject to a cap based on two key figures
• The first figure is the unused part of the surrendering company's available losses (the surrenderable amounts), after taking into account any amounts already allocated to other claims
• The second figure is the unrelieved part of the claimant company's available total profits for the claim period, after deducting any relief already given
• The group relief actually given is limited to the lower of these two figures