Corporation Tax Act 2010 section 141

Sections 139 and 140: supplementary

Section 141 provides supplementary rules for handling multiple group relief claims, determining the order in which they are processed, and ensuring fair outcomes when standard time-apportionment calculations produce unjust results.

• When two or more group relief claims are made at the same time, the claiming company or companies may elect the order in which the claims are treated as having been made; if no election is made, HMRC will direct the order.
• The amount of group relief given on an earlier claim is calculated on the basis that relief on that claim is given before relief on any later claim, so each claim is measured taking into account only those claims that preceded it.
• If the standard time-apportionment proportions used in sections 139 and 140 produce an unjust or unreasonable result in a particular case, those proportions must be modified so far as necessary to achieve a just and reasonable outcome.
• Elections as to the ordering of simultaneous claims are made through the company tax return process or, where applicable, by notice to HMRC.

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