Annex 1: Minor changes in the law Change 25: Group relief: restriction of surrender by company owned by consortium: section 148 Example 1
Under section 405(2) of ICTA, S is assumed to make a group relief claim to cover its profits. S’s corresponding accounting period (see section 413(2A) of ICTA) is the 12 months ended 31 December 2009. So the assumed claim is for £2000 and (because no other companies are involved) that is the amount of the “potential group relief”. So C’s “loss or other amount” available for surrender to M1, M2 etc is reduced under section 405(1) of ICTA to £8000, the net loss of the group as a whole.