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Lesson 361

DTR and transferring losses

In this lesson, you'll learn how double taxation relief (DTR) works and the strategic approach to transferring group losses to minimise your tax liability.

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In this lesson

  1. 0:00 Double taxation relief and group losses overview
  2. 1:02 Track Star case study setup
  3. 2:01 Group relief structure and strategy
  4. 3:15 Double taxation relief calculation
  5. 4:02 Optimal loss allocation workings
  6. 5:02 Losses carried forward summary

About this lesson

Double taxation relief applies when a company's overseas profits are taxed both abroad and in the UK—you can claim relief for the lower of the two tax amounts, but unrelieved foreign tax arises when the overseas rate exceeds the UK rate. This is essential for ATX (Advanced Taxation) and relates directly to group relief planning in your exam. You'll work through a practical scenario involving a UK company with overseas permanent establishment profits, two subsidiaries, and group losses to surrender. The key principle is to use losses strategically so that the company's taxable total profits don't fall below its overseas profits—this prevents creating additional unrelieved foreign tax. The lesson walks you through the calculation of DTR, the order in which to claim relief (brought-forward losses first, then group relief), and how to allocate group losses across multiple companies to achieve the most tax-efficient outcome, including identifying losses carried forward.

Duration: 5m

Transcript

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