Corporation Tax Act 2010 section 188BA

Overview of Chapter

Section 188BA provides an overview of the rules that allow a company to surrender carried-forward losses and other amounts to other group companies.

  • A company may surrender losses and other amounts that have been carried forward to one of its accounting periods to another group company.
  • The basic rules for how such losses and amounts can be surrendered are set out in a separate provision dealing with the mechanics of surrender.
  • A number of restrictions apply which limit the losses and amounts that may be surrendered, including restrictions on pre-April 2017 losses and losses of dual-resident companies.
  • The chapter as a whole establishes both how amounts may be surrendered and how the surrenderable amount is calculated.

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