Emma Hardwick Authors Article on Restrictions on Group Relief Surrenders for U.K. Corporation Tax Purposes During Sale Negotiations

August 1, 2014

In the August 1 issue of Tax Journal, Ms. Hardwick authored the article, “Loss of ability to surrender group relief during sale negotiations.” The article considers the point during sale negotiations at which a target within a group for U.K. corporation tax purposes may lose the ability to surrender or receive amounts eligible for “group relief” (for example, trading losses) prior to completion of a sale of the target. Restrictions on the utility of group relief may arise from breaking the group relationship by loss of beneficial ownership of shares in the target, or under statute from the point “arrangements” are in place for the target to be degrouped.