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HMRC internal manual

Company Taxation Manual

CTSA: group relief: simplified arrangements: partial acceptance of an application

Regulation 9 SI1999/2975

Sometimes, rather than refusing an application to enter into a simplified arrangement (CTM97740), it will be more appropriate to accept it but only in part. Regulation 9 allows you to exclude a particular company from an arrangement where:

  • it is not part of the group (CTM97680),
  • it has failed to comply with its obligations under the Corporation Tax Acts, or
  • it is a company in relation to which a person is acting as an insolvency practitioner.

For this purpose an insolvency practitioner means a liquidator, provisional liquidator, administrator, administrative receiver or a supervisor of a voluntary arrangement under Part I of the Insolvency Act 1986. This reflects our view that the appointment of an insolvency practitioner causes the previous owners of a company to lose control of it, breaking the group relationship.

Any case where partial acceptance is being considered on the basis of the second bullet should be referred to CTISA (Technical), see ‘Technical Help’ on the left bar.

For excluding a company from a simplified arrangement following a change of circumstances see CTM97760.