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HMRC internal manual

Company Taxation Manual

Tax elected funds (TEFs): breaches of conditions: multiple breaches of separate conditions

Under regulation 69Z68 SI2006/964, in addition to the consequences relating to breaches of particular conditions of the TEF regime, there may also be consequences of multiple breaches of different conditions.

The rules relating to multiple breaches work as follows:

  • where there has been a breach of at least two different conditions; and,
  • where there have been four such breaches in a period of ten years (beginning with the first day of the accounting period in which the first breach occurs),

then HMRC will issue a termination notice to the manager of the TEF.