Introduction Equity holders Overview Section 147: Conditions 1 and 2: surrenderable amounts including trading loss
575.This section restricts the amount of trading losses that can be surrendered by a company owned by a consortium. It is based on section 403ZA of ICTA.
576.Subsection (1) applies the section to consortium condition 1: that is, a case that does not involve a link company.
577.Subsection (2) extends the section to consortium condition 2: that is, cases involving a link company (L) where the surrendering company (C) is owned by a consortium.
578.Subsection (3) is the rule that a trading loss within section 37 (“sideways relief”) is not available for group relief to the extent that relief could be given for it within the surrendering company.
579.Subsection (4) explains how the rule in this section interacts with the rule in section 148: this section applies first to reduce the surrenderable losses.