Corporation Tax Act 2010 section 188CK

Deductions from total profits

Section 188CK sets out how group relief for carried-forward losses is given effect by way of a deduction from the claimant company's total profits, including the ordering of that deduction relative to other reliefs and the prohibition on double relief.

• When a claimant company claims group relief for carried-forward losses, the relief takes the form of a deduction from its total profits for the claim period, equal to all or part of the surrendering company's surrenderable amounts
• The deduction is made after most other reliefs available at the same step in the corporation tax computation, but before reliefs for losses, capital allowances or loan relationship deficits carried back from a later period
• The deduction is subject to the corporate loss restriction (the cap on the total amount of profits that may be relieved by carried-forward losses) and to the specific limitations in Chapters 4 and 5 depending on the type of claim
• Corporation tax relief cannot be given more than once for the same amount, whether by combining group relief for carried-forward losses with another relief given to the surrendering company, or by giving group relief for carried-forward losses twice

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