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 CTA09/S780 (CIRD40510) the time immediately before company X ceases to be a member of the group; or
- for a case within CTA09/S785 (CIRD40550) the time immediately before X ceases to satisfy the qualifying condition.
And the relevant group is:
- for a case within CTA09/S780 the group of which company X was a member at the relevant time,
- for a case within CTA09/S785 the ‘second group’ (Y’s group in the example in CIRD40550).