CTM80205 - Groups: group relief: HMRC鈥檚 approach to 鈥渁rrangements鈥� - SP3/93 and ESC C10

CTA10/S154

SP3/93 {#} sets out the way HMRC interprets the legislation involving 鈥榓rrangements鈥� and 鈥榦ption arrangements鈥�. CTA10/S173 is about 鈥榦ption arrangements鈥�, and there is guidance on this at CTM81090, it has significance for all grouping tests that depend on measuring entitlements to profits and to assets in a winding up. 皇冠体育app guidance on this is at CTM81000 onwards.

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皇冠体育appre is no advance clearance procedure for transactions affected.

For arrangements entered into in accounting periods ending before 1 March 2012 SP3/93 should be considered in conjunction with ESC C10 {#}. ESC C10 was enacted into legislation in 2012, so for arrangements entered into in accounting periods ending on or after this date CTA10/S155A and CTA10/S155B exclude certain commercial arrangements from falling within S154(3) and S155(3) (CTM80185).