Emma Hardwick considers the point during sale negotiations at which a target may lose the ability to surrender or receive group relief
Many groups contain entities with amounts eligible for surrender by way of group relief under CTA 2010 Part 5 such as trading losses or excess non-trading loan relationship debits. In the absence of consolidated group filing for corporation tax purposes it is important for groups to be able to surrender eligible amounts between group entities. Eligible amounts can be set off against the corporation tax liabilities of recipient entities thereby reducing the group’s total corporation tax bill and its effective corporation tax rate. In addition in the context of an M&A deal the ability to surrender group relief to the target for the pre-completion period will be an important...
