»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp percentages shown in this diagram indicate beneficial ownership of ordinary share capital and you should assume that the arrangements rules (CTA10/Ss146A, 146B, and 155) do not apply.

»Ê¹ÚÌåÓýapp votes and entitlement to profits and assets on winding up follow the shareholdings shown (see CTA10/Ss151(4) for Q, R, S, and T (CTM80535), and Ss143(3) and 144(3) for the ownership proportions of W, X, Y, and Z in H (CTM80540 and CTM80545)).

All parties have an accounting period of 12 months to 31 December 2011, and the percentages shown remain constant throughout the accounting period.

H, a holding company, has the following trading subsidiaries shown above: Q, R, S, and T..

W, X, Y, and a bank Z are members of the consortium. Bank Z holds the shares in H on trading account. Each of the four companies in the consortium has ample profits to absorb any relief surrendered by the holding company and its subsidiaries.

»Ê¹ÚÌåÓýapp accounts of the following companies for the 12 months to 31 December 2011 give results as follows.

Company	Description	Amount
H	excess management expenses	£5,000
Q	trading losses	£4,000
R	trading losses	£6,000
S	trading losses	£2,000
T	trading losses	£1,000

All the companies, including Z, give consent to claims for consortium relief. »Ê¹ÚÌåÓýapp members of the consortium may then obtain consortium relief as follows.

W

Consortium relief	Amount
25% of H’s excess management expenses	£1,250
25% of Q’s loss	£1,000
25% of R’s loss	£1,500
No relief in respect of S’s loss (see below)	NIL
25% of T’s loss	£250
Consortium relief	£4,000

X

Consortium relief	Amount
25% of H’s excess management expenses	£1,250
25% of Q’s loss	£1,000
25% of R’s loss	£1,500
No relief in respect of S’s loss (see below)	NIL
25% of T’s loss	£250
Consortium relief	£4,000

Y

Consortium relief	Amount
25% of H’s excess management expenses	£1,250
25% of Q’s loss	£1,000
25% of R’s loss	£1,500
No relief in respect of S’s loss (see below)	NIL
25% of T’s loss	£250
Consortium relief	£4,000

Under CTA10/S153(3) there is no relief due to any of the members of the consortium for S’s loss because S is not a 90% trading subsidiary of H (CTM80535).

Z is not entitled to any relief (CTA10/S132(4) - CTM80530) because a profit on the sale of the shares it holds in H would be a trading receipt.

Losses, etc, to carry forward

»Ê¹ÚÌåÓýapp balance of losses and other amounts not surrendered may be carried forward by each company as follows.

Description	Company H	Company Q	Company R	Company S	Company T
Excess management expenses	£5,000	-	-	-	-
Trading losses	-	£4,000	£6,000	£2,000	£1,000
Less surrendered as group relief	£3,750	£3,000	£4,500	-	£750
Carried forward	£1,250	£1,000	£1,500	£2,000	£250