Revenue Note for Guidance
419 The relevant accounting period, etc
(1) For the purposes of this Chapter, “the relevant accounting period” is —
- in a case where the ownership tests to determine whether there is a group relief situation have to be applied as at a particular time (that is, group relief apart from consortium relief), the accounting period current at that time, and
- where the ownership tests have to be applied by reference to a particular accounting period (that is, consortium relief), the accounting period in which the ownership tests have to be applied.
(2) For the purposes of sections 413 to 418 a loan to a company is treated as a security whether or not it is secured and, if secured, irrespective of the nature of the security.
Relevant Date: Finance Act 2017