Revenue Note for Guidance

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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