Corporation Tax Act 2010 section 140

Unrelieved part of claimant company's available total profits

Section 140 explains how to calculate the portion of a claimant company's available total profits that remains unrelieved by group relief, taking into account different accounting periods and any earlier group relief claims already made against those profits.

• The unrelieved amount equals the claimant company's available total profits for the overlapping period, less any group relief previously claimed against those profits for that period
• Where the surrendering and claimant companies have different accounting periods, the claimant company's available total profits are time-apportioned to the overlapping period shared by the two accounting periods
• Any earlier group relief claims that overlap with the current claim period are identified and time-apportioned to the common period, and the total of these previously claimed amounts is deducted from the available total profits
• For non-UK resident claimant companies, available total profits exclude any profits from activities that are exempt under a double taxation agreement