http://www.legislation.gov.uk/ukpga/2010/4/section/139Corporation Tax Act 2010An Act to restate, with minor changes, certain enactments relating to corporation tax and certain enactments relating to company distributions; and for connected purposes.texttext/xmlenStatute Law Database2026-04-02Expert Participation2026-01-15 Part 5Group reliefChapter 4Claims for group relief<Emphasis>General limitation on amount of group relief to be given</Emphasis><CommentaryRef Ref="key-a46d4907a422975fcbcab9405dd44215"/>Unused part of the surrenderable amounts1391The unused part of the surrenderable amounts is the amount equal to—athe surrenderable amount for the overlapping period (see subsection (2)), lessbthe amount of prior surrenders for that period (see subsections (3) to (5)).2To determine the surrenderable amount for the overlapping period—atake the proportion of the surrender period included in the overlapping period, andbapply that proportion to the surrenderable amounts for the surrender period.The surrenderable amount for the overlapping period is the amount given as a result of paragraph (b).3To determine the amount of prior surrenders for the overlapping period—aidentify any prior claims for the purposes of this section (see subsection (4)), andbtake the steps set out in subsection (5) in relation to each such claim.The amount of prior surrenders for the overlapping period is the total of the previously used amounts given at Step 3 in subsection (5) for all the prior claims.4A claim is a prior claim for the purposes of this section if—ait is a claim by any company for group relief in respect of the whole or a part of the amounts that, in relation to the current claim, are the surrendering company's surrenderable amounts for the surrender period,bit is made before the current claim, andcit has not been withdrawn.5These are the steps referred to in subsection (3)(b) to be taken in relation to each prior claim.Step 1Identify the overlapping period for the prior claim.Step 2Identify any period that is common to the overlapping period for the current claim and the overlapping period for the prior claim. If there is a common period, go to Step 3. If there is no common period, there is no previously used amount in relation to the prior claim (and ignore Step 3).Step 3Determine the previously used amount of group relief in relation to the prior claim (see subsection (6)).6To determine the previously used amount of group relief in relation to a prior claim—atake the proportion of the overlapping period for the prior claim that is included in the common period identified at Step 2 in relation to that claim, andbapply that proportion to the amount of group relief given on the prior claim.The previously used amount of group relief in relation to the prior claim is the amount given as a result of paragraph (b).7For the meaning of “the overlapping period” see section 142.Pt. 5 applied (with effect in accordance with s. 148 of the amending Act) by Finance Act 2012 (c. 14), s. 125 (with s. 147, Sch. 17)Pt. 5 excluded (with effect in accordance with Sch. 18 para. 63 of the amending Act) by Finance Act 2016 (c. 24), Sch. 18 para. 20(5)Pt. 5 modified by 2009 c. 4, s. 1218ZDB(2) (as inserted (for specified purposes and with effect in accordance with Sch. 6 paras. 20, 21(1)(a) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 6 para. 1 (with Sch. 6 para. 21(3)))Pt. 5 modified (with effect in accordance with reg. 1(2) of the amending S.I.) by The Risk Transformation (Tax) Regulations 2017 (S.I. 2017/1271), regs. 1(1), 10, 11Pt. 5 applied (with modifications) (24.2.2022) by Finance Act 2022 (c. 3), Sch. 2 para. 47(4)Ss. 138-142 applied (1.4.2022 in relation to accounting periods beginning on or after that date) by Finance Act 2022 (c. 3), s. 51(1), Sch. 7 para. 10(1)Ss. 138-142 applied (with modifications) (14.7.2022) by Energy (Oil and Gas) Profits Levy Act 2022 (c. 40), Sch. 1 para. 11 (with ss. 15(1), 16(1), 17)Pt. 5 excluded (14.7.2022) by Energy (Oil and Gas) Profits Levy Act 2022 (c. 40), s. 1(5)(e) (with ss. 15(1), 16(1))