CTM80630 | Consortia: group relief: date of arrangements
From HM Revenue & Customs · Company Taxation Manual
Following the decision in Shepherd v Law Land plc [63TC692], a consortium group relationship that would otherwise exist is only broken by reason of ‘arrangements’ within while those arrangements are in existence. A consortium group relationship is not necessarily broken for the whole of an accounting period during which arrangements have existed.
Where S155 arrangements interrupt an existing consortium group arrangement during an accounting period, the provisions of apply ().