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Official guidance
Company Taxation Manual

CTM80500 · Consortia: group relief

  • CTM80502 · Introduction
  • CTM80510 · Application of rules
  • CTM80515 · Claims
  • CTM80520 · Claims: consent to be given
  • CTM80525 · Claims: rules limiting
  • CTM80530 · Meaning of ‘members of the consortium’ and ‘company owned by a consortium’
  • CTM80535 · 90% subsidiary
  • CTM80540 · Amount of relief: claimant is a member of the consortium: claims based on consortium condition 1
  • CTM80545 · Amount of relief: claimant is company owned by a consortium: claims based on consortium condition 1
  • CTM80550 · Extension to companies in same group as member of the consortium
  • CTM80555 · Claim by company in same group as member of the consortium: claims based on consortium condition 2
  • CTM80560 · Surrender by company in same group as member of the consortium: consortium condition 3
  • CTM80570 · Items eligible for relief: potential restriction on surrender of trading losses
  • CTM80580 · Group and consortium claims both possible: surrendering company is both owned by a consortium and a member of a group
  • CTM80585 · Group and consortium claims both possible: claimant company is both owned by a consortium and a member of a group
  • CTM80587 · Control arrangements: claimant is member of the consortium
  • CTM80588 · Control arrangements: claimant is company owned by the consortium
  • CTM80590 · Diagram showing meaning of various terms
  • CTM80600 · Arrangements to transfer the company owned by a consortium to another group or consortium
  • CTM80605 · Arrangements: disqualifying relief
  • CTM80615 · Arrangements: definitions
  • CTM80620 · Enabling arrangements
  • CTM80625 · Direct arrangements
  • CTM80630 · Date of arrangements
  • CTM80635 · Information about arrangements
  • CTM80640 · SP3/93 and ESC C10
  • CTM80670 · Example: consortium relief generally
  • CTM80675 · Example: surrender by member of the consortium and by a member of its group, overlapping periods and company joining link company’s group
  • CTM80680 · Example: claim by company owned by a consortium from a company in the same group as a member of the consortium
  • CTM80685 · Example: restriction where group claims possible
  • CTM80690 · Example: restriction where group claims are possible by companies which are not owned by the consortium
  • CTM80695 · Example: restriction where group claims are possible
  • CTM80696 · Example: restriction of surrender of trade losses where company owned by consortium has other profits
  1. Consortia: group relief: contents
  2. Consortia: group relief: information about arrangements

CTM80635 | Consortia: group relief: information about arrangements

From HM Revenue & Customs · Company Taxation Manual

FA73/S32

For arrangements entered into before 13 August 2009, the guidance in CTM80200 should be followed if:

  • a company makes a claim to consortium relief,

and

  • there is reason to believe that any arrangements within ICTA88/S410(2) to (6) (the precursor to CTA10/S155, described at CTM80605) or ICTA88/Schedule 18/Paragraph 5(3) (the precursor to CTA10/S169(2), described at CTM81085) exist or may have existed at any time material to the claim.

FA73/S32 was repealed with effect from 13 August 2009 as part of the review of information powers. Only the information powers at FA08/Schedule 36 may be used from 13 August 2009.

Where you started your compliance check before 13 August 2009 you must not use a particular power in FA08/Schedule 36 to seek information or documents that you were in a position to seek (see CH21050) from that person before Schedule 36 applied if either:

  • there was no corresponding power before that date, or

  • the corresponding power could not have been so used.

So where the information powers in FA73/S32 would have been used (and no other information powers from prior to FA08 applied) you should follow the guidelines in CTM80200 and where appropriate restrict the FA08/Schedule 36 powers accordingly.

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