A company (the surrendering company) may surrender trading losses and other amounts eligible for relief from corporation tax to another company within its group (the claimant company) for the claimant company to set off against its own profits for corporation tax purposes. The companies are within the same group where one is the 75% subsidiary of the other or both are 75% subsidiaries of a third company and certain other conditions are met. The group relationship may be established by reference to non-UK resident companies.

For a detailed examination of the group relief rules, see Practice note, Group and consortium relief. For information on tax grouping more generally, with links to notes on the treatment of groups in relation to specific taxes, see Groups of companies: tax toolkit.