CTA10/S137 provides that the group relief that a company may be allowed must not exceed the amount of the claimant company's total profits actually arising in the accounting period in accordance with CTA10/S4(2).
This means total profits after any relief actually claimed or automatically off-set under the Taxes Acts except reliefs that are restricted under CTA10/Part7ZA and that cannot be quantified until the amount of the group relief claim is known. See CTM05010 for more on restricted reliefs.
Examples of unrestricted reliefs that are deducted are:
•any relief for UK property business losses of the same accounting period under CTA10/S62(3),