CTM80170 | Groups: group relief: arrangements, effect 1
From HM Revenue & Customs · Company Taxation Manual
effect 1
Effect 1 in is that there are arrangements in place of any kind (whether or not in writing) whereby a company, or a successor to it , could:
cease to be a member of the same group as a second company,
and
become a member of the same group as a third company.
This is subject to exclusions for certain commercial arrangements as set out in /Ss155A and 155B (), and to the definition of arrangements in ()
‘Successor’
One company is a successor of another if it carries on, in whole or in part, a trade which the other company has ceased to carry on in certain circumstances where a balancing charge would not be chargeable on the ceasing company – . The circumstances are where:
(transfers of trade without a change of ownership) applies in relation to the companies as, respectively, the successor and the predecessor within the meaning of that Chapter, or
the two companies are connected with each other in accordance with .
‘Third company’ ()
This means a company which, ignoring the effect of any arrangements is not a member of the same group as the company in to which the arrangements refer.