The group relief rules contain special provisions for computing the amount of relief which can be surrendered by one member of the group to another. This case is about how those rules apply where a company has chargeable gains in a period but allowable losses arising in earlier periods which reduce or eliminate chargeable gain. The question is whether the chargeable gain reduces the amount of relief available for surrender. It was widely thought that it did. But this case establishes that it does not.David Goldberg KC (instructed by Messrs PricewaterhouseCoopers, Chartered Accountants) for the Appellant