Corporation Tax Act 2010 section 357JF

Availability of relief

Section 357JF sets out how group relief applies where a company has Northern Ireland losses or mainstream losses, ensuring that losses are matched against the corresponding type of profits first before being set against the other type.

• For group relief purposes, a trading loss of a company that has both Northern Ireland and mainstream activities is split into Northern Ireland losses and mainstream losses, rather than being treated as a single trading loss.
• Where a Northern Ireland loss is surrendered as group relief, it must be set against Northern Ireland profits first before any remaining amount can be relieved against mainstream profits.
• Where a mainstream loss (i.e. one that is not a Northern Ireland loss) is surrendered as group relief, it must be set against mainstream profits first before any remaining amount can be relieved against Northern Ireland profits.
• The standard definition of "trading loss" continues to apply, but is modified by this matching requirement so that losses and profits of the same type are paired together as far as possible.