Taxes Consolidation Act 1997 section 688

Treatment of group relief

Section 688 applies a two-way ring-fence to group relief claims involving petroleum profits and losses, ensuring that petroleum trade results can only be set off against other petroleum trade results within a group.

• Group relief claims against a claimant company's petroleum profits are restricted to losses from a surrendering company's petroleum or mining trade, or charges on income paid wholly and exclusively for the purposes of such a trade.
• Charges on income paid to a connected person do not qualify for group relief against petroleum profits.
• Conversely, petroleum or mining trade losses and related charges of the surrendering company cannot be set off against any profits of the claimant company other than its petroleum profits.
• The definitions of "claimant company" and "surrendering company" are imported from section 411, which governs the general group relief regime for 75% groups.