Corporation Tax Act 2010 section 269ZV

Group allowance allocation statement: requirements and effects

Section 269ZV sets out the formal requirements for a group allowance allocation statement and the rules governing how the group deductions allowance may be allocated among group members, including the maximum amounts that can be allocated and the consequences of non-compliance.

  • The statement must identify the group, specify the nominated company's accounting period, state the group deductions allowance, and list the group members receiving an allocation along with the amounts and periods for which they are allocated.
  • The maximum allocation to any listed company is capped by a formula that time-apportions the group deductions allowance based on the number of overlapping days the company was both a group member and within the nominated company's accounting period.
  • If a statement breaches the allocation limits, a revised statement must be submitted within 30 days; failing that, HMRC may amend the statement and must notify all listed companies.
  • The normal time limits for amending a company tax return do not apply where the amendment arises from the submission of a group allowance allocation statement.

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