CTM81080 | Groups & consortia: groups - entitlement to profits or assets available for distribution: varying and limited rights - effect

From HM Revenue & Customs · Company Taxation Manual

and

There are four different possible determinations of profits and of assets in a winding-up where and apply as well as and . The four possible combinations of accounting periods and treatment of rights are:

  • rights of a different accounting period, treating limited rights as waived,

  • rights of the current accounting period, treating limited rights as waived,

  • rights of a different accounting period (not treating limited rights as waived),

  • rights of the current accounting period (not treating limited rights as waived).

Rights of current accounting periodRights of a different accounting period
Limited rights treated as waivedLimited rights treated as waived
No special treatment of rightsNo special treatment of rights

The lowest percentage entitlement to profits arising from these combinations is taken for the purposes of .

The lowest percentage entitlement to assets in a winding-up is taken for the purposes of .