Corporation Tax Act 2010 section 937B

Group schemes and single company schemes

Section 937B classifies risk transfer schemes as either group schemes or single company schemes, and explains how the rules are modified when only a single company is involved.

• A risk transfer scheme is a "group scheme" if at least one other associated company is also a party to the scheme alongside the main company (company A)
• The "relevant group" comprises company A together with every other associated company that is a party to the same scheme
• A "single company scheme" is any risk transfer scheme that does not qualify as a group scheme
• For single company schemes, references to the relevant group or its members are read as references to company A alone, and certain aggregation provisions are disregarded