CG46365 - Groups: rebasing: elections out of kink test: relevant time

`»Ê¹ÚÌåÓýapp relevant timeâ€� is defined by TCGA92/SCH3/PARA9 (1) as the earliest of the following

  • the first time any company in the group other than an `outgoing companyâ€� makes a disposal to which Section 35 applies
  • the time immediately after an `incoming companyâ€� first joins the group
  • the time when the principal company makes an election.

»Ê¹ÚÌåÓýapp first of these events is the one which is most likely in practice. »Ê¹ÚÌåÓýapp third event will apply to companies which have taken the opportunity to make an election at any time before 6 April 1990.