SolvedCTM80630 | 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 CTA10/S155 while those arrangements are in existence. A consortium group relationship is not necessarily broken for the whole of an accounting period during which CTA10/S155 arrangements have existed.
Where S155 arrangements interrupt an existing consortium group arrangement during an accounting period, the provisions of CTA10/S138 apply (CTM80215).