{
  "url": "https://openlegislation.uk/corporation-tax-act-2010/section-269ZR",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2010/section-269ZR.json",
  "legislation": "ukpga/2010/4",
  "legislation_title": "Corporation Tax Act 2010",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2010",
  "path": "section/269ZR",
  "kind": "section",
  "number": "269ZR",
  "heading": "Deductions allowance for company in a group",
  "text": "(1) This section makes provision as to the deductions allowance of a company for an accounting period where, at any time in the period—\n(a) the company is a member of a group, and\n(b) one or more other companies within the charge to corporation tax are members of that group.\n(2) The company's deductions allowance for the accounting period is the sum of—\n(a) any amounts of group deductions allowance allocated to the company for the period in accordance with sections 269ZS to 269ZV, and\n(b) the appropriate amount of non-group deductions allowance of the company for the period,\nup to a limit of £5,000,000.\n(3) The “appropriate amount of non-group deductions allowance” of the company, for the accounting period, is—\nDNGDAC×£5,000,000where—\n“DNG” is the number of days in the period on which the company is not a member of a group that has another member that is a company within the charge to corporation tax, and\n“DAC” is the total number of days in the period.\n(4) If the accounting period is less than 12 months—\n(a) the appropriate amount of non-group deductions allowance, and\n(b) the limit in subsection (2),\nare proportionally reduced.\n(5) See section 269ZYA for further provision about the deductions allowance for a company without a source of chargeable income which is a member of a group.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 7ZA inserted (with effect in accordance with Sch. 4 para. 190 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 4 para. 16"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 269ZR(5) inserted (with effect in relation to accounting periods beginning on or after 1.4.2020) by Finance Act 2020 (c. 14), Sch. 4 paras. 32, 42 (with Sch. 4 paras. 43-46)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/4/section/269ZR",
    "retrieved_at": "2026-10-29T09:10:29.433154+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}