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CTA09/S369

Carry forward of group relief

听

Whenever there is a group relief claim but no debits for impairment (after any reduction in bad debts brought about under CTA09/S365) in the group accounting period, CTA09/S369 ensures that the amount of that group relief claim is taken into account when considering subsequent restrictions under CTA09/S365. This caters for situations where the claimant makes a group relief claim but defers charging the corresponding impairment debit to a later year.

In the example at CFM35670, WD Ltd wrote off 拢100,000 of a 拢200,000 loan to a consortium company in Year 1. This debit was restricted to 拢68,000 because of a group relief claim of 拢32,000.

In Year 2 there is a group relief claim of 拢130,000 but no impairment debit.

In the following period (Year 3) there is no group relief claim, but there is an impairment debit of 拢70,000.

Year 2听

CTA09/S368 reduces the group relief claim to 拢62,000 by past impairment loss relief given of 拢68,000. This reduced group relief claim is allowed, but because there is no relevant net debit in the year, this sum is also carried forward under CTA09/S369. It will be treated as group relief of the following period for the purposes of CTA09/S365 only.

Year 3听

CTA09/S365 reduces the impairment debit by group relief. Here there is no group relief claim of the year, but group relief of 拢62,000 has been carried forward under CTA09/S369. The impairment debit is restricted by 拢62,000, leaving a relievable debit of 拢8,000.

Example

Y	Impairment	Adj imp鈥檛	Cumulative adj	Cum net debits	Group relief	Adj group relief	S367 cf	Total relief
1	100,000	68,000	32,000	68,000	32,000	32,000	0 听	100,000
2	0	0	32,000	0	130,000	62,000	62,000	62,000
3	70,000	8,000	94,000	8,000	0	0	0	8,000

听