Corporation Tax Act 2010 section 269CI

Allocation of carried-forward loss allowance within a group

Section 269CI allows a building society that is part of a group to share its carried-forward loss allowance with other banking companies in the same group, subject to notification requirements to HMRC.

• A building society with unused carried-forward loss allowance (initially £25,000,000) may allocate some or all of it to other banking companies within its group
• A formal statement of allocation must be submitted to HMRC detailing the amounts allocated and the recipient companies, and this must be filed by the time the first relevant tax return or amendment is submitted
• Once submitted, the statement of allocation cannot be amended or withdrawn, unless a re-allocation is made under section 269CJ
• The allocation is only effective if all the procedural requirements of this section have been complied with