CTM36315 | Particular topics: company winding up TAAR: condition B
From HM Revenue & Customs · Company Taxation Manual
and S404A (3)
and S404A only apply where the company being wound up was a close company, see onwards, at any time in the two years immediately preceding the start of the winding up.
Example
Company A starts winding up proceedings on 1 May 2016. If it had been a close company at any point during the period 2 May 2014 to 1 May 2016, S396B or S404A can apply where the other conditions are met.