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HMRC internal manual

Corporate Intangibles Research and Development Manual

HM Revenue & Customs
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Intangible assets: groups: degrouping: reallocation between group members: relevant time and relevant group

Relevant time and group for the purposes of reallocation

As mentioned in CIRD40705, the two companies making an election to reallocate a taxable credit on degrouping must both be members of the ‘relevant group’ at the ‘relevant time’.

In the case of company X reallocating a taxable credit on degrouping to company Y, the‘relevant time’ is:

  • for a case within FA02/SCH29/PARA58 (CIRD40510) the time immediately before company X ceases to be a member of the group,
  • for a case within FA02/SCH29/PARA60 (CIRD40550) the time immediately before X ceases to satisfy the qualifying condition.

And the relevant group is:

  • for a case within paragraph 58 the group of which company X was a member at the relevant time,
  • for a case within paragraph 60 the ‘second group’ (Y’s group in the example in CIRD40550).