Corporation Tax Act 2010 section 188CE

The group condition

Section 188CE sets out the group condition that must be satisfied for carried-forward losses to be surrendered as group relief between two companies.

  • The group condition requires both the surrendering company and the claimant company to be members of the same group of companies.
  • Both companies must also be "UK related" — meaning they have a sufficient connection to the UK.
  • These requirements mirror the existing group relief rules under Part 5 of the Corporation Tax Act 2010.
  • The definition of "UK related" is provided separately in section 188CJ of the Act.

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