Corporation Tax Act 2010 section 188EJ

Condition 3 or 4: surrendering company not controlled by claimant company etc.

Section 188EJ is an anti-avoidance rule that reduces group relief for carried-forward losses by 50% where arrangements have been put in place to prevent a consortium member (or link company) from controlling the surrendering company, and those arrangements form part of a tax-motivated scheme.

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