Corporation Tax Act 2010 section 269DI

Group allowance allocation statement: requirements and effect

Section 269DI sets out the detailed requirements for a group allowance allocation statement, including the information it must contain, the limits on how much surcharge allowance can be allocated to each banking company, and what happens if the statement does not comply with the rules.

  • The statement must identify the group, specify the nominee's accounting period, state the group surcharge allowance, list the banking companies receiving allocations, and specify the amounts and periods for each allocation.
  • The maximum surcharge allowance allocable to any banking company for a given accounting period is capped by a formula based on the number of overlapping days between that company's accounting period and the nominee's accounting period, and total allocations cannot exceed the group surcharge allowance.
  • If a statement does not comply with the allocation limits — whether at the time of submission or because it later ceases to comply — the nominated company must submit a revised compliant statement within 30 days, failing which HMRC may amend the statement as they see fit.
  • HMRC may make regulations covering the form and manner of submission, information requirements, and circumstances in which late or non-compliant statements may be treated as valid.

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