CTM80230 - Groups: group relief: non coinciding accounting periods or group relationships - unused part of the surrenderable amounts

CTA10/S139

CTA10/S139 defines 鈥渦nused part of the surrenderable amounts鈥� for the purpose of CTA10/S138 (CTM80210).

In particular, the rules cater for the cases where:

  • the surrendering company and the claimant company have different accounting periods or are not in a group relationship for the whole periods; or
  • there are multiple claims for the surrendering company鈥檚 losses and other amounts.
  • S139(1) defines the 鈥渦nused part of the surrenderable amounts鈥� as being equal to:
  • the surrenderable amount for the overlapping period, less,
  • the amount of prior surrenders for the overlapping period.

The meaning of 鈥渙verlapping period鈥� is given by CTA10/S142 (CTM80225).

Calculate the surrenderable amount for the overlapping period:

  • establish the surrendering company鈥檚 total losses and other amounts available for surrender (CTM80110) for its accounting period, then,
  • time-apportion that surrenderable amount to the overlapping period, by reference to the proportion of the surrender period included in the overlapping period.

Although the usual method of apportionment is time apportionment, under CTA10/S141(3), some other just and reasonable apportionment may be used if time apportionment would be unjust or unreasonable, see CTM80260.

Step 2

Once you have calculated this amount you will need to reduce it by any prior surrenders for the overlapping period (CTM80240).