Corporation Tax Act 2010 section 188BB

Surrender of carried-forward losses and other amounts

Section 188BB sets out the rules allowing a company to surrender certain carried-forward losses and other amounts to another group company as group relief for carried-forward losses.

• A company may surrender specific types of post-1 April 2017 carried-forward losses — including trading losses, non-trading loan relationship deficits, non-trading losses on intangible fixed assets, management expenses, and UK property business losses — to another group company, provided those losses are eligible for relief against total profits
• Life insurance companies may surrender carried-forward BLAGAB trade losses, but only the portion that remains after first setting those losses against the company's own BLAGAB trading profits for the period
• The surrender is carried out by the surrendering company consenting to one or more claims for group relief for carried-forward losses made by the claimant company
• Various restrictions on what may be surrendered apply under sections 188BC to 188BJ, including restrictions on pre-1 April 2017 losses and losses of dual resident companies