Transferring/ Claiming Loss Items to/ from More than One Company

This page explains the priority of transferors, claimants and loss items in situations where there are multiple transferors or claimants; and when the exact number of transferors or claimants has not been ascertained.

Single Transferor, Multiple Claimants

Where a transferor company wishes to transfer its loss items to more than one claimant company, the loss items must be fully deducted from the available assessable income of the first claimant company before any excess loss items are deducted from the available assessable income of the second claimant company and so on.

Multiple Transferors, Single Claimant

Similarly, a claimant company may claim loss items from one or more transferor companies within the same group. The loss items transferred from the first transferor company must be fully deducted from the assessable income of the claimant company before loss items from a second transferor company can be deducted.

Priority of Loss Items Transferred or Claimed

In both cases, the loss items are transferred/ claimed in accordance with the priority spelt out in the companies' respective Form GR-A (619KB) and Form GR-B (639KB).

When the transferor company is unable to ascertain the exact number of claimant companies to transfer its loss items to, because the tax positions of the transferor/ claimant have not been finalised yet, the company may specify a list of claimant companies even though the combined provisional assessable income of these claimant companies may exceed the provisional quantum of loss items available for set off.

Similarly, the claimant company may specify a list of transferor companies even though the combined provisional quantum of loss items of the transferor companies available for set off is higher than the provisional assessable income of the claimant company.

Priority by Transferor Takes Precedence

When the priority list submitted by the transferor company is inconsistent with the list submitted by the claimant company, the order of priority specified by the transferor company takes precedence.

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