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HMRC internal manual

Corporate Finance Manual

Loan relationships: consortia companies and impairment: how the restriction works: example

When the Chapter 7 restriction applies: example

FD Ltd is a consortium company. It is owned

40% by RT plc, the holding company of a large group

40% by WD Ltd, a subsidiary of KX plc

20% by MC Ltd, a singleton company.

Any amount that is written off a loan made


RT plc (consortium member) or any of its subsidiaries (group members)

WD Ltd (consortium member), its holding company or any of its fellow group members, or

MC Ltd (consortium member)


FD Ltd

or, if FD Ltd is a holding company, any subsidiary (within CTA10/Part5) of FD Ltd

will fall within CTA09/PT5/CH7.