LTCs, Losses And Subvention Payments

Question

I have a client who has an ordinary company with A & B as directors and 50/50 shareholding which has losses carried forward. They have another company which is a look through company (LTC) with the same shareholding but one of them is a director. Can we do subvention payments to offset the profits in the LTC company?

Answer

No. LTCs cannot group with other companies to receive a loss offset or make a subvention payment.