Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Priority definition

What does Priority mean? Priority describes the order in which competing proprietary rights and security interests take effect against an asset and the sequence in which secured creditors are paid on enforcement or insolvency. It is a cross‑context concept informed by statute and case law (for example, land registration legislation, companies legislation on registration of charges, and equitable rules on notice). In practice, priority is usually set by time and method of perfection: creation and registration of mortgages/standard securities over land (e.g. under the Land Registration Act 2002 in England and Wales and the 2012 Scottish legislation), registration of company charges (at Companies House under...

UK corporation tax: ordering and interaction of loss reliefs for loss‑making companies, including group relief, carried-forward rules, CILR and the gross profits test

Published by a LexisNexis Tax expert

Practice notes

A company belonging to a loss relief group that has sustained any category of losses eligible to be surrendered by way of Group relief (including group relief for carried-forward losses) can, in the absence of any further Rules or constraints, have more than one route for deploying that loss. For instance, it might either surrender the loss for group relief or set the loss against its own Profits in the present or a subsequent accounting period of its own. That said, various provisions curtail the company’s freedom by, for example, stipulating the order in which particular reliefs must be used first and specifying the types of profits against which those losses may properly be matched. This Practice Note outlines the rules—both the choices and the limitations—relevant to trading losses, excess capital allowances, non‑trading loan relationship deficits, UK property business losses, management expenses, and non‑trading intangible fixed asset losses that may arise. The overriding principle is that relief cannot be secured for the same loss more than once—whether within the same company or through group relief arrangements...

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Web page updated on 21/05/2026

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