CIRD40710 | Intangible assets: groups: degrouping: reallocation between group members: relevant time and relevant group

From HM Revenue & Customs · Corporate Intangibles Research and Development Manual

Relevant time and group for the purposes of reallocation

As mentioned in CIRD40705, the two companies making an election to reallocate a taxable credit on degrouping must both be members of the ‘relevant group’ at the ‘relevant time’.

In the case of company A reallocating a taxable credit on degrouping to company B, the‘relevant time’ is:

for a case within CTA09/S780 (CIRD40510) the time immediately before company A ceases to be a member of the group; or
for a case within CTA09/S785 (CIRD40550) the time immediately before B ceases to satisfy the qualifying condition.

And the relevant group is:

for a case within CTA09/S780 the group of which company A was a member at the relevant time,
for a case within CTA09/S785 the ‘second group’ (B’s group in the example in CIRD40550).