Corporation tax – Group relief for Paper P6 (UK)

Test your understanding: answers

(1). CX Ltd is associated with seven companies at some point in the year ended 31 March 2015 as set out below.

• MK Ltd, its remaining 100% subsidiary and its 60% subsidiary.
• JN Ltd and its two subsidiaries.
• RT Ltd (because it and JN Ltd are controlled by Mr Pereta).

Therefore, the upper and lower limits for CX Ltd would be divided by eight.

(2). WF Ltd will be able to surrender losses to BG Ltd if it is a consortium company. It will be a consortium company if:

• it is not a 75% subsidiary of another company, and
• companies, each of which own at least 5% of WF Ltd’s ordinary share capital, together own at least 75% of its ordinary share capital. So a further 55% of its ordinary share capital must be owned by companies, each of which owns a minimum of 5%.

(3). Statement A is false
Group relief is set off against the recipient company’s total profits of the corresponding accounting period. Accordingly, the maximum amount of group relief a company may receive is an amount equal to its total profits.

Total profits are after deducting all reliefs for the current period and amounts brought forward. Current period trading losses must be deducted regardless of whether or not a claim is made to offset the current period losses against total profits.

Statement B is false
The claim to carry back losses for offset against total profits of the previous 12 months is an all or nothing claim; it cannot be restricted to a particular amount.