Introduction Equity holders Overview Section 183: Payments for group relief
732.This section takes outside the tax system any payments for group relief. It is based on section 402 of ICTA.
733.Originally (from 1953 to 1967) a form of group relief was available, based on “subvention” payments from one company to another. The payment was allowed as a deduction, reducing the profits of the paying company; and it was a taxable receipt of the company receiving the payment. Such payments are no longer required by United Kingdom tax law. But they may be made by agreement between group members. This section ensures that they are neither allowed as a deduction nor taxed.