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(b) in the case of a company, sections 243, 308(4) and 396(2) and subsections (1), (2) and (6) of section 420.

(c) the total amount of the loss referred to in subsection (1) of section 420 for the chargeable period and the total amount of the excess referred to in subsection (2), (3) or (6) of that section for that period shall each be treated for the purposes of Chapter 5 of Part 12 as reduced by 50 per cent,

(2) In computing the corporation tax chargeable for any accounting period of a company, any charges on income paid by the company in the accounting period, in so far as paid out of the company’s profits brought into charge to corporation tax, shall be allowed as deductions against the total profits for the period reduced by any other relief from corporation tax other than group relief in accordance with section 420.

(b) Where a capital allowance in respect of machinery or plant to be made to a company in an accounting period is a specified capital allowance, arising other than in the course of a trade, to which sections 308(4) and 420(2) apply, those allowances shall not be available—

(ii) for relief under section 420(2), except to the extent that the amount can be set off against profits of—

(II)sections 308(4) and 420(2) shall apply,

(f) details in respect of capital allowances surrendered under section 420(4) in the period to which the return relates, insofar as those capital allowances pertain to specified capital allowances, including details of the relationship between the claimant company and the surrendering company (both within the meaning of section 411(2));

(b) Sections 305(1)(b), 308(4) and 420(2) shall not apply in relation to capital allowances—

such that the aggregate of the amounts of the lease payments which are payable, or which would be payable if the relevant lease payments were the actual amounts payable under the lease, after any time exceeds the aggregate of the amounts of such relevant lease payments which would have been payable after that time if the events in subparagraph (i) or (ii) had not taken place, then, notwithstanding subsection (6)(a), unless it is shown that the change or the termination was effected for bona fide commercial reasons, the lease (including the terminated lease) shall be treated as if it were at all times a relevant lease, and relief given under Part 9, Chapter 1 or 2 of this Part, or section 396 or 420, which would not have been given if the lease was a relevant lease, shall be withdrawn.

(II) the amount of any loss which was set off under section 307, 308, 396 or 420 against profits, or

(a) sections 305(1)(b), 308(4) and 420(2) shall not apply as respects that allowance, and

Where a person incurs capital expenditure of the type to which subsection (7) of section 284 applies and an allowance is to be made in respect of that expenditure under that section, sections 305(1)(b), 308(4) and 420(2) shall not apply as respects that allowance.

(ii) against the total profits of a claimant company under section 420(1), except to the extent of the amount of income from a qualifying shipping trade included in those total profits,

(2) Notwithstanding subsections (1) and (6) of section 420 and section 421, where in any accounting period the surrendering company incurs a relevant trading loss or an excess of relevant trading charges on income, that loss or excess may not be set off for the purposes of corporation tax against the total profits of the claimant company for its corresponding accounting period.

(a) corresponds to an amount of a kind that, for the purposes of section 420 or 420A, could be available for surrender by means of group relief by a company resident in the State,

(2) Group relief in accordance with section 420 for an accounting period shall be allowed as a deduction against the claimant company’s total profits for the period before reduction by any relief derived from a subsequent accounting period, but as reduced by any other relief from tax (including relief in respect of charges on income under section 243(2)).

(i) be set off against the total profits under section 420,

(i) section 420 to accounting periods, profits, losses, allowances, expenses of management and charges on income of the surrendering company,

(I) be set off against the total profits under section 420,

(20) (a) Notwithstanding subsections (1) and (6) of section 420 and section 421, where in an accounting period ending before 31 December 2009 the surrendering company has incurred a loss in a trade, the operations or activities of which consist of or include dealing in residential development land, then an amount of the loss, determined in accordance with paragraph (b), may not be set off for the purposes of corporation tax against the total profits of the claimant company for its corresponding accounting period.

(b) subject to subsection (4)(b)(ii), shall not otherwise be entitled to relief in respect of the loss or to surrender relief under section 420(1) in respect of the loss.

then, for the purpose of enabling the company to surrender the excess referred to in paragraph (a) by means of group relief, section 420(6) shall apply as if—

(c) amounts set off or surrendered under section 420 or 420A in an accounting period that falls wholly or partly within the period commencing on 1 January 2018 and ending on 31 December 2023, or

(2) Where relief in respect of interest paid, being interest treated as a charge on income, is claimed by virtue of section 420(6), any question under this section as to what benefit might be expected to accrue from the transaction under which that interest is paid shall be determined by reference to the claimant company (within the meaning of section 411(2)) and the surrendering company (within the meaning of that section) taken together.

(3) The amount of any expenditure to be treated under subsection (2) as incurred at the time that a trade or profession has been set up and commenced shall not be so treated for the purposes of section 381, 396(2) or 420 396(2), 396A, 396B, 420, 420A or 420B.

(c) any amounts referred to in paragraph (a) or (b) claimed by a claimant company under section 420(6),

(c) amounts set off under section 420 or 420A other than:

(i) interest treated as a charge on income that may be set off under section 420(6), but for this Part,

(ii) expenses of management that may be set off under section 420(3), but for this Part, and