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The losses rules apply to the amount of Company D’s understated profit and the PLR for the inaccuracy is calculated in the context of the aggregate loss position of the group. (GOV.UK)

It would write off its investment in IT equipment and machinery against its deliberately understated profits. (TaxWatch)

Under the new provisions this is not possible so understated profits may lead to a penalty for a group company even though there might be losses elsewhere in the group, which the group might be able to use after the event against these profits. (parliament.uk)