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HMRC internal manual

Capital Gains Manual

Groups: rebasing: elections out of kink test: companies joining/leaving group

The position is more complex when companies join or leave a group but the basic principles remain the same. The legislation identifies a time from which an election takes effect in relation to a group of companies and calls this `the relevant time’. As a general rule the election by the principal company covers all the companies in the group at the relevant time and only those companies.