伊人直播

Structural outline

What can be transferred between group members?

Meaning of trading loss

Meaning of excess capital allowances

Meaning of deficits on non-trading loan relationships

Meaning of qualifying charitable donations

Meaning of UK property business loss

Meaning of excess management expenses

Meaning of non-trading losses on intangible fixed assets

Special rules that apply to 鈥渞elevant amounts鈥�

Order of relief for amounts which can be surrendered

Claims for relief

Which companies may claim and surrender group relief?

The group relationship

Group relief and partnerships

Shareholding rule plus the entitlement to profits/assets tests

Applying the entitlement to profits/assets tests

Overview of the arrangements rules

Arrangements, effect 1

Arrangements, effect 2

Arrangements, effect 3

Exclusion of certain arrangements

Enabling arrangements

Direct arrangements

Date of arrangements

Contingent arrangements

HMRC鈥檚 approach to 鈥渁rrangements鈥� - SP3/93 and ESC C10

Examples of arrangements

Non coinciding accounting periods or group relationships - overview

Non coinciding accounting periods or group relationships - multiple claims

Non coinciding accounting periods or group relationships - the order which claims are dealt with

Non coinciding accounting periods or group relationships - overlapping period

Non coinciding accounting periods or group relationships - unused part of the surrenderable amounts

Non coinciding accounting periods or group relationships - unrelieved part of claimant company鈥檚 available total profits

Non coinciding accounting periods or group relationships - amount of any prior surrenders attributable thereto

Non coinciding accounting periods or group relationships - amount of any previous claims attributable thereto

Non coinciding accounting periods or group relationships - example

Non coinciding accounting periods or group relationships 鈥� time apportionment is not the only permitted method

Non coinciding accounting periods or group relationships - use of management accounts

Non coinciding accounting periods or group relationships - apportioned amount not to exceed total loss

The international aspect - overview

The international aspect - permanent establishments

UK permanent establishment of non-resident company

UK permanent establishment of non-resident company - tax relief in a foreign jurisdiction

Meaning of non-UK profits

Meaning of non-UK tax

UK permanent establishment of non-resident company - tax relief in a foreign jurisdiction - credit and exemption countries

UK permanent establishment of non-resident company 鈥� determining tax relief in a foreign jurisdiction for an EEA resident company

UK permanent establishment of non-resident company 鈥� determining amount available for surrender in the UK for an EEA resident company

UK permanent establishment of non-resident company - clawing back group relief for losses relieved in foreign jurisdiction for an EEA resident company

UK permanent establishment of non-resident company - losses exempted by double taxation agreements

UK permanent establishment of non-resident company - amounts which can be surrendered

Overseas permanent establishment of UK resident company

Overseas permanent establishment of UK resident company - meaning of attributable to overseas permanent establishment

Overseas permanent establishment of UK resident company - meaning of tax relief in a foreign jurisdiction

Overseas permanent establishment of UK resident company - foreign 鈥榯ie-breaker鈥� rules

The international aspect - accounting period straddling 1 April 2000

Available total profits

Exclusion of double allowances

Cases of difficulty

Avoidance

Example - surrender of trading losses

Example - surrender of excess capital allowances

Example - surrender of excess management expenses

Example - surrender of excess qualifying charitable donations