CTM80410 | Groups: group relief: cases of difficulty
From HM Revenue & Customs · Company Taxation Manual
If:
you have any difficulty in applying the group relief rules, or
there is evidence of manipulation which cannot be countered by the rules in CTA10/S154 (CTM80165) or CTA10/S151(4) and Chapter 6 of Part 5 of CTA10 (CTM80155)
Then you should submit such cases to a CT Technical Specialist.