CTM80205 | Groups: group relief: HMRC’s approach to “arrangements” - SP3/93 and ESC C10
From HM Revenue & Customs · Company Taxation Manual
SP3/93 {#} sets out the way HMRC interprets the legislation involving ‘arrangements’ and ‘option arrangements’. is about ‘option arrangements’, and there is guidance on this at , it has significance for all grouping tests that depend on measuring entitlements to profits and to assets in a winding up. The guidance on this is at onwards.
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
(This content has been withheld because of exemptions in the Freedom of Information Act 2000)
There is no advance clearance procedure for transactions affected.
For arrangements entered into in accounting periods ending before 1 March 2012 SP3/93 should be considered in conjunction with ESC C10 {#}. ESC C10 was enacted into legislation in 2012, so for arrangements entered into in accounting periods ending on or after this date and exclude certain commercial arrangements from falling within S154(3) and S155(3) ().