I have a client company (professional services) which is about to go into members voluntary liquidation. Over the years it built up substantial revenue reserves. During the recession years it incurred trading losses which have been carried forward and offset against profits in recent years. However, the close company surcharge has been payable during the loss making years (ie. because of the substantial build up of revenue reserves). The company has incurred a terminal loss and I was wondering if this loss could be used to claim back some of the surcharge paid in the last 3 years of trading?