Section 188FA Payments for group relief for carried-forward lossesF1

the surrendering company and the claimant company have an agreement between them in relation to losses and other amounts of the surrendering company (“the agreed loss amounts”),

group relief for carried-forward losses is given to the claimant company in relation to the agreed loss amounts, and

as a result of the agreement the claimant company makes a payment to the surrendering company that does not exceed the total amount of the agreed loss amounts.

is not to be taken into account in determining the profits or losses of either company for corporation tax purposes, and

for corporation tax purposes is not to be regarded as a distribution.