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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Consortia: group relief: SP3/93 and ESC C10

SP3/93 sets out the way in which HMRC interprets the legislation involving both ‘arrangements’ and ‘option arrangements’. For further guidance see CTM80205.

For arrangements entered into in accounting periods ending before 1 March 2012 SP3/93 should be considered in conjunction with ESC C10. ESC C10 was enacted into legislation in 2012, so for arrangements entered into in accounting periods ending on or after this date CTA10/S155A and CTA10/S155B exclude certain commercial arrangements from falling within S155(3) (CTM80620).