CTM80135 - Groups: group relief: meaning of UK property business loss
CTA10/S99(1)(e), CTA10/S102, CTA10/S105
A loss from a UK property business can be surrendered and claimed as group relief (CTM80105 and PIM4240). A UK property business loss means a loss made in a UK property business in the surrender period 바카라 사이트� CTA10/S102(1). CTA10/S102(2) provides that it does not include a loss brought forward but treated as made in the surrender period as a result of CTA10/S62(5). However, property business losses arising after 1 April 2017 that are carried forward may be relieved as group relief for carried forward losses (CTA10/Part 5A) (CTM82000).
A loss from a UK property business is a 바카라 사이트榬elevant amount바카라 사이트� for the group relief provisions, so can only be surrendered to the extent that the total of the surrendering company바카라 사이트檚 relevant amounts exceeds the 바카라 사이트榩rofit-related threshold바카라 사이트� (or 바카라 사이트榞ross profit바카라 사이트� in surrendering periods ended before 20 March 2013; see CTA10/S105, CTM80142). This is the case regardless of whether the surrendering company uses any of the relevant amounts against its own profits.
The calculation will need to take into account the prescribed order of surrender of relevant amounts (see CTM80143).
A non-commercial property loss is not eligible for relief under the loss relief rules. CTA10/S99(2) prevents the surrender of losses that are 바카라 사이트渘ot eligible for Corporation Tax relief바카라 사이트�. So non-commercial property losses cannot be surrendered as group relief as they are excluded under CTA10/S64.