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HMRC internal manual

Company Taxation Manual

Groups & consortia: consortia - group income: election - validity

ICTA88/S248 (1) and (2)

An election becomes effective:

  • three months after the date of the notice of election, unless you notify the companies that the validity of the election is not established to your satisfaction,


  • from the date you notify the companies concerned that you are satisfied with the validity of the election,

whichever is the earlier.

The notifications should be made by letter. No special form is provided. The Inspector to whom the notice of election was sent should send the notification. He or she should send a separate notification to each company.

Where you are not satisfied with the validity of an election and you cannot reach agreement with the companies, you should:

  • notify each company concerned, not later than three months from the date of the election, and
  • refer the case to CTIAA (Technical).

Where there is an election under ICTA88/S247 (4) to make payments made on or before 11 May 2001in full, and the recipient company is a charity, you should send:

  • a report, and
  • a copy of the correspondence

to the Audit Unit, IR Savings, Pensions, Share schemes (the Edinburgh office for Scottish cases) before you issue an acceptance of the election.

A valid ICTA88/S247 (4) election made prior to FA96, and which refers only to charges, will be treated as extending to loan relationship interest.