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(1)In section 1114 “the actual reduction in tax liability” means the sum of—
(a)amounts within subsection (2), and
(b)amounts within subsection (3).
(2)The amounts within this subsection are those by which the liability of the claimant to pay corporation tax has been reduced in any accounting period in consequence of qualifying R&D relief in respect of expenditure attributable to the research and development project.
(3)The amounts within this subsection are those by which the liability of any other company (“C”) to pay corporation tax has been reduced in any accounting period in consequence of a surrendered loss.
(4)A “surrendered loss” means a loss which—
(a)is surrendered to C by the claimant under section 402 of ICTA (surrender of relief between members of groups and consortia), and
(b)arises in consequence of qualifying R&D relief in respect of expenditure attributable to the project.
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