75 per cent subsidiary, meaning

90 per cent subsidiary, meaning

Accelerated payment notices

Acquisition of trading stock

Agreement to extend import agreement/option to sell shares in importer

Alternative finance arrangements

Appointment of receivers over the whole property of a company

Arrangements in place to deny the surrender of group relief

Arrangements that do not restrict availability of relief

Bad or doubtful debts

Banks Tier 2 capital resources


Beneficial ownership

Capital allowance excess, surrenderable amount

Capital allowances surrendered

Capital allowances, surrender of

Carried-forward amounts, conditions for claims


Form of

Losses of UK and non-UK resident companies

Time limit



Amounts surrendered by EEA-related companies

Amounts surrendered by UK-related companies

Authorised company


Deduction from total profits


Limitation on amount given

Members of both group and consortium

Outside time-limits


Simplified arrangements

Two or more claims, priority of claims

Claims and adjustments

Alterations to claims or amounts surrendered

Amounts available for surrender

Consent to surrender

Consortium claims, exclusion of share dealing companies


Larger/more complex groups

Late claims

Recovery of additional tax as a result of reduction in claim

Simplified arrangements



Company, definition


Consortium relief

Amount which can be claimed

Arrangements preventing control in place

Bad debts

Claimant company not controlled by surrendering company

Companies owned by consortiums

Conditions to be met

Discrimination according to the place of residence

Freedom of establishment



Link company established in EEA

Loan relationships, bad debts/impairment

Meaning of consortium

National legislation excluding the transfer of losses within the national territory by a consortium company

Proportion of voting power held by company, based on

Qualifying holding company

Residence requirement imposed on link company

Surrendering company not controlled by claimant company

Transfers of companies owned by consortiums

Control of company, arrangements whereby control can be obtained by another person

Controlled foreign companies

Convertible shares or securities

Corporation tax self-assessment

Claims and adjustments

Claims for more or less than amount available for surrender

Claims to be included in return

Consent to surrender

Content of claims

Excessive, assessment to recover


Joint amended returns

Notice of consent

Notice of consent requiring amendment of return

Reduction in amount available for surrender

Time-limit for claims

Withdrawal or amendment

Decided stamp duty cases

Deduction of loss incurred by another member from assessable income


Determination of EU law question following CJEU judgment

Determination of relationship between companies


Explanation of terms


Groups of companies


Transfer of companies, arrangements for

Disposal of real estate

Disqualifying arrangements

Double taxation exempt, activities which are

Double taxation relief, non-discrimination provision

Dual resident companies

Dual resident investing companies

EEA-related companies

Conditions which must be met




Overlapping period

Surrenderable amount

Entitlement to profits available for distribution

Entitlement, losses on realised loans

Equity holder, meaning

Equity holders

Equity holders, profits and assets available for distribution

Entitlement to distribution of profits

Equity holder, meaning


Non-resident companies

Normal commercial loan, meaning

Ordinary shares, meaning

Quoted parent company test

Restricted right to dividends

Shares or securities with restricted/temporary rights

Tier two capital

Use of relevant company's assets

Exception for certain joint venture arrangements

Exception for mortgage arrangements


Failure of a member state to fulfil obligations


Group transfers, tax avoidance

Group, meaning

HMRC's refusal to exercise a statutory discretion permitting adjustments to claims outside statutory time limits

Holding company, meaning

How relief is given

Insurance companies

Intangible fixed assets, surrenderable amount

Intra-group transfers following corporation acquisitions

Joint venture arrangement

Joint venture company

Land and buildings transaction tax

Late claims, loss-buying scheme

Limitation on amount given

Consortium condition, claim based on


Overlapping period, meaning

Two or more claims, priority of claims

Unrelieved part of claimant company's available total profits

Unused part of surrenderable amounts

Limited liability partnerships

Lloyd's underwriters, restriction

Loan creditor, meaning

Loan relationships

– see also Loan relationships

Bad debts/impairment

Non-trading deficit

Loss relief group litigation, High Court jurisdiction

Loss-making company and acquiring company members of same group

Losses incurred by subsidiaries in other member states

Date for determining definitive losses

Freedom of establishment

Invalid claims, no-possibilities test fulfilment

Quantification of losses

Management expenses, surrenderable amount


Member states freedom of establishment

Members of same group throughout whole of period

Members of the same group

Mortgage arrangement

Nature and conditions



New consideration, meaning

Non-resident companies

Non-resident companies trading through UK permanent establishment

Non-resident subsidiaries

Clarification of judgment and costs

Losses and profits in different jurisdictions, successive claims

No possibilities test

Valid claims, time-limits

Non-UK tax, meaning

Normal commercial loan, meaning

Oil extraction activities

Oil taxation

Ordinary share capital

Ordinary shares, meaning

Overseas losses of non-resident companies


Ownership of share capital


Partnerships generally

Payments for relief surrendered

Payments not to be taken into account

Profits and assets available for distribution

Basic rules


Non-resident companies

Option arrangements

Shares or securities with limited/temporary rights

Profits and assets available for distribution, equity holder's entitlement to

Amounts referable to company's UK trade

Joint venture companies, transfer of shares or securities/suspension of member's voting rights

Lower alternative proportion

Mortgages secured by shares or securities/exercise of rights

Non-resident companies

Option arrangements

Proportion of profits available

Relevant accounting period, meaning

Shares or securities with limited rights

Shares or securities with temporary rights

Winding up, proportion of profits available

Property business losses, surrenderable amounts

Qualifying groups

Recovery of SDLT

Restriction, joint assessment


Restrictions on availability of relief

Restrictions on relief

First disqualifying arrangement


Stamp-duty reconstruction

Sale and leaseback relief

Seventy-five percent subsidiary test

Share dealing companies

Stamp duty

Stamp duty land tax


HMRC guidance on para. 4ZA


Subsequent sale of properties acquired as trading stock


75 per cent subsidiary, issued share capital

75 per cent, meaning

90 per cent, meaning

Companies treated as members of the same group

Consortiums, companies owned by

Loss-buying scheme, late claims

Receipts of

Sale of


Amount available, deduction of allowable losses of past periods from chargeable gains

Arrangements when company leaving group

Surrenderable amount (EEA-related companies)

Administrative provisions

Amount which can be claimed

Anti-avoidance provisions, unallowable overseas losses

Capital allowances

Conditions which must be met

Determination, steps to be followed

EEA group condition, meaning

Recomputation of loss according to UK principles

Residence and where activities are carried on

Surrenderable amount (UK-related companies)

Alternative finance arrangements

Capital allowance excess

Dual resident companies

Equivalence condition


Intangible fixed assets

Management expenses

Non-resident companies trading through UK permanent establishment

Non-UK profits, meaning

Non-UK tax, meaning


Trading losses

UK property business losses

UK resident company with foreign permanent establishment

Surrendering company non-resident

Surrendering losses and other amounts

Alternative finance arrangements, restriction of losses etc. surrenderable

Capital allowances excess, meaning

Charitable donations

Dual resident companies, restriction on losses etc. surrenderable


Intangible fixed assets, non-trading loss

Leasing plant and machinery

Management expenses, meaning

Non-resident companies, restriction on losses etc. surrenderable

Non-UK profits, meaning

Property income losses

Restrictions on losses etc. that may be surrendered

Specified losses and other amounts that may be subject to a claim

Trading loss, meaning

UK property business loss

Surrenders by non-resident company resident/trading in the EEA

Accounting periods, assumptions as to

Assumptions to be made in recalculating EEA amount

Calculation of amount to be surrendered

Capital allowances, assumptions as to

EEA related definitions

EEA tax loss condition, companies non-resident in EEA territory

EEA tax loss condition, companies resident in EEA territory

Equivalence condition

Excluded amounts


Places in which activities carried on, assumptions as to

Precedence condition

Qualifying loss condition

Recalculation of EEA amount

UK residence, assumptions as to

Trading company, meaning

Trading losses, surrenderable amount

Trading or capital receipts

Transfer of rights



Losses of non-resident company


Tax avoidance

Transfers of companies, arrangements for

Arrangements, meaning

Company owned by consortium

Joint venture companies, transfer of shares or securities/suspension of member's voting rights

Member of group of companies

Mortgage secured by shares or securities/right not exercised

Statutory body

Successor companies, meaning

Trustee savings banks

UK resident company with foreign permanent establishment

UK-related companies

Amount which can be claimed

Conditions to be met

Cosortium conditions

Surrenderable amounts


Cases involving successive transactions





Recovery of SDLT

Withdrawal of old and making of new claims after expiry of ordinary statutory time limits

Withdrawal of relief