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HMRC internal manual

Company Taxation Manual

Groups & consortia: consortia - group income: multiple elections

The parts of ICTA88/S247 relating to payments of dividends were repealed from 6 April 1999 onwards. The remainder of Section 247 was repealed by FA01 in relation to payments of interest or charges made after 11 May 2001.

You can accept a multiple election covering three or more companies.

The election should normally be made to the Inspector dealing with the company owned by the consortium. It will be the responsibility of the Inspector to:

  • be satisfied that the election is valid, after any necessary consultation with any other Inspector involved,
  • notify any other Inspector involved of the terms and effective date of the election,
  • send a report to the Audit Unit, IR Savings, Pensions, Share Schemes (the Edinburgh office for Scottish cases), where the recipient is a charity.


  • adequately set out the facts necessary to show that the companies are entitled to make the election,
  • be signed by a director, secretary or other person duly authorised to act on behalf of each company concerned,
  • make clear, as regards any two signing companies, whether their joint election extends (if applicable) to:
    • dividends paid by either of the companies to the other,


  • charges on income/loan relationship interest paid by either company to the other.