Corporation Tax Act 2010 section 676CI

Interpretation of Chapter

Section 676CI defines the key terms "co-transferred company" and "related" company used throughout this Chapter, which deals with restrictions on carried-forward losses following a change in company ownership.

• A "co-transferred company" is one that is related to the transferred company both immediately before and immediately after the change in ownership.
• Two companies are "related" if they satisfy the group condition or any of consortium conditions 1 to 4, regardless of which company is treated as the claimant and which as the surrendering company.
• The group condition broadly requires the two companies to be members of the same group, as defined for group relief on carried-forward losses purposes.
• The four consortium conditions cover various arrangements where companies are connected through consortium ownership structures, again as defined for group relief on carried-forward losses purposes.