Corporation Tax Act 2010 section 84

The gross assets requirement

Section 84 sets out the gross assets limits that a company must satisfy in order for a claim to share loss relief to be valid.

• A single company's gross assets must not exceed £7 million immediately before the relevant shares are issued, and must not exceed £8 million immediately afterwards
• The same £7 million and £8 million limits apply to the combined group assets of a parent company and its qualifying subsidiaries
• When calculating group assets, any intra-group items such as rights against, shares in, or securities of other group members are excluded
• A "single company" is one with no qualifying subsidiaries, while a "parent company" is one that has one or more qualifying subsidiaries