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HMRC internal manual

Company Taxation Manual

Consortia: group relief: date of arrangements

CTA10/S155

Following the decision in Shepherd v Law Land plc [63TC692], a consortium group relationship that would otherwise exist is only broken by reason of ‘arrangements’ within CTA10/S155 while those arrangements are in existence. A consortium group relationship is not necessarily broken for the whole of an accounting period during which CTA10/S155 arrangements have existed.

Where S155 arrangements interrupt an existing consortium group arrangement during an accounting period, the provisions of CTA10/S138 apply (CTM80215).