Consortium relief

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Introduction

Consortium relief enables losses of a consortium company to be transferred to consortium members in proportion to the consortium member’s interest in the consortium company, and vice versa. Consortium relief is a flexible relief which is available in several different scenarios which are discussed further below.

Prior to 1 April 2017 consortium relief was only available for current year losses. For losses arising after 1 April 2017 these rules have been relaxed and when post 1 April 2017 losses are carried forward most types can be surrendered as consortium relief. These rules are similar to the consortium relief rules for current year losses set out below but there are several conditions and anti-avoidance provisions. For further details see the Consortium relief for carried-forward losses post 1 April 2017 section in the Group relief for carried-forward losses guidance note.

Definition of consortium company

A 'consortium company’ is a company which is 75% owned by consortium members.

Consortium members are companies which own at least 5% of the consortium company.

Overseas companies are included when deciding whether there is

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