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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
Updated
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Other tax rules on corporate debt: group mismatch schemes: meaning of scheme period

For the purposes of the group mismatch rules, the ‘scheme period’ includes the whole period during which the scheme has effect. This will includes all periods in which the impacts of the scheme are realised beginning with the first act or omission under the scheme and ending with the last.

If the scheme period is uncertain then in determining whether the scheme is a GMS then any reasonable assumption as the scheme period may be made.