What are Pre-Grouping Tax Losses, and how do they affect a Tax Group?

Pre-Grouping Tax Losses are the unutilized Tax Losses of a Subsidiary that joins a Tax Group. These losses must be utilized before the Tax Group’s own Tax Losses. If a Tax Group is formed, losses incurred before the Corporate Tax commencement date cannot be claimed. Therefore, if a Tax Group is established from 1 January 2024, pre-Grouping Tax Losses of its members cannot be claimed.