Commentary

D2.208 Consortium claims—types of consortium structures

Corporate tax
Corporate tax | Commentary

D2.208 Consortium claims—types of consortium structures

Corporate tax | Commentary

D2.208 Consortium claims—types of consortium structures

Where a company is in a consortium (D2.207A), the consortium company can claim or surrender relief if it is either a1:

  1.  

    •     trading company which is owned by the consortium and is not a 75% subsidiary (D2.106) of any company, or

  2.  

    •     trading company which is a 90% subsidiary (D2.106) of a holding company which is owned by the consortium and which is not a 75% subsidiary of any company other than the holding company. Note when establishing whether a subsidiary is a 90% subsidiary, the profit distribution test (D2.206) and notional winding-up test

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