Section 188FA — Corporation Tax Act 2010: Payments for group relief for carried-forward losses

Payments for group relief for carried-forward losses 188FA 1 This section applies if—

a the surrendering company and the claimant company have an agreement between them in relation to losses and other amounts of the surrendering company (“the agreed loss amounts”),

b group relief for carried-forward losses is given to the claimant company in relation to the agreed loss amounts, and c as a result of the agreement the claimant company makes a payment to the surrendering company that does not exceed the total amount of the agreed loss amounts.

2 The payment—

a is not to be taken into account in determining the profits or losses of either company for corporation tax purposes, and b for corporation tax purposes is not to be regarded as a distribution.