Corporation Tax Act 2010 section 188DG

Sections 188DC and 188DE: meaning of "the overlapping period"

Section 188DG defines "the overlapping period" for the purposes of calculating limits on group relief for carried-forward losses under sections 188DC and 188DE.

  • The overlapping period is the time that falls within both the surrendering company's surrender period and the claimant company's claim period.
  • Any part of this common period during which the relevant relief condition is not satisfied is excluded from the overlapping period.
  • Excluded parts are instead treated as portions of the surrender period and claim period that fall outside the overlapping period, which affects how the relief limits are calculated.
  • The relief condition is whichever qualifying condition the claim is based on — the group condition or one of the four consortium conditions.

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