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HMRC internal manual

Company Taxation Manual

Groups & consortia: consortia - group income: election - form of

The parts of ICTA88/S247 relating to payments of dividends were repealed from 6 April 1999 onwards. The remainder of Section 247 was repealed by FA01 in relation to payments of interest or charges made after 11 May 2001.

There is no special form of election. You can accept the election, for payments prior to the above dates, if it is signed on behalf of each company by a person duly authorised to act on behalf of the company. It should set out the facts necessary to show that the companies are entitled to make the elections. It should also make clear whether the election is made under:

  • ICTA88/S247 (1), or
  • ICTA88/S247 (4), or
  • both ICTA88/S247 (1) and ICTA88/S247 (4).

Where applicable, the election should show whether it extends to payments made by either company to the other.