the language is not consistent so it is confusing. tax crosses both accounting and legal disciplines so that complicates it.
re the available fraction, it is a complicated beast to actually compute.
but the essence of it is to discourage a company from acquiring another company (LossCo) purely for its tax losses. The disincentive works by limiting the amount of usable tax losses in the LossCo to the proportion of income it contributes to the Group income (loosely called the "available fraction".
so if LossCo remains loss making, the tax losses are effectively quarantined.
the language is not consistent so it is confusing. tax crosses...
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