Jurisdiction(s):
United Kingdom

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Key definition

Consortium relief definition

What does Consortium relief mean? Consortium relief allows corporation tax losses and other group-relief amounts to be surrendered between a company owned by a consortium and the corporate members of that consortium, typically to align tax capacity across joint venture structures. In the UK, the rules are set out in the Corporation Tax Act 2010; in Ireland, comparable provisions appear in the Taxes Consolidation Act 1997. Usage is broadly consistent across England & Wales, Scotland, Northern Ireland and Ireland, though detailed conditions and cross‑border scope differ. A company is consortium‑owned if it is not a 75% subsidiary of another company and at least...

UK corporation tax: consortium relief—calculating maximum claims and surrenders, including ownership proportion, linked claims, trading loss priority, interaction with group relief, carried-forward losses and anti-avoidance

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Practice notes

consortium relief

Consortium relief describes an extension of the group relief regime that permits losses to be surrendered and claimed between companies that are not sufficiently connected to constitute a group, but where joint ownership of a company creates a consortium. For details on what amounts to a consortium, and wider guidance on consortium relief, see Practice Note: Consortium relief. The categories of losses that qualify for group relief also qualify for consortium relief; see Practice Note: Group relief—types of losses that can be surrendered. As with group relief claims made by members within a loss relief group, the quantum of any consortium relief claim between companies owned by, and members of, a consortium (including through link companies) is capped in specified circumstances. This Practice Note sets out those caps and conditions in the context of consortium relief for current year losses, and for consortium relief where losses are carried forward under the applicable restrictions and any related limitations...

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Web page updated on 22/05/2026

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