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Jurisdiction(s):
United Kingdom
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Key definition
Group definition

What does Group mean? Group describes, in practice, the corporate family around a company: that company, its subsidiaries, its holding (parent) company, and the subsidiaries of that holding company. While “group” itself is a descriptive label, the constituent terms are defined in legislation: in the UK, Companies Act 2006 defines “subsidiary” and “holding company” (s.1159) and “parent/subsidiary undertaking” and “group undertaking” (ss.1161–1162); in Ireland, the Companies Act 2014 defines “subsidiary” and “holding company” (eg s.7). Practitioners commonly incorporate those statutory definitions by reference. Typical contractual usage is: in relation to a company, that company, any subsidiary or holding company [from time to...

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UK corporation tax group relief: conditions, claim administration (consents, time limits, withdrawals, simplified procedure) and intra-group payment arrangements, including carried-forward losses

Published by a LexisNexis Tax expert
Practice notes
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Conditions for Claiming Group relief

Where a Company (the surrendering company) has a loss or other amount that is eligible to be surrendered for group relief in an accounting period (the surrender period), it may surrender that loss as group relief, and then another company (the claimant company) may claim the relief as a deduction against its total profits if all of the following apply:

  • the surrendering company consents to the claim
  • there is a period common to both the surrender period and the claimant company's accounting period in which the claim is made (the overlapping period)
  • the surrendering company and the claimant company are members of the same Group at some point during the overlapping period
  • both the surrendering company and the claimant company are UK related, meaning either a UK resident company or a non-UK resident company within the charge to UK corporation tax

This is subject to:

  • the loss being of a type that can be surrendered
  • the amount of loss being available for surrender

For more detail on the type, and the amount, of loss that can be surrendered, see Practice Notes: How much group relief can be surrendered and claimed?...

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Web page updated on 21/05/2026

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