Corporation Tax Act 2010 section 188DA

Overview

Section 188DA introduces the chapter that sets out the limitations on the amount of group relief that can be claimed for carried-forward losses under section 188CB.

• This chapter deals with caps and restrictions on the amount of carried-forward loss relief that one group company can claim from another.
• The claims covered are those made under section 188CB, which allows surrender of carried-forward losses between companies in a group or consortium relationship.
• The group relationship includes situations where the claimant company is owned by a consortium and the surrendering company is either a consortium member or belongs to the same group as a "link company".
• The purpose of these limitations is to ensure that the relief claimed does not exceed the amounts properly available to either the surrendering or the claimant company.