[13 January 1993]

Introduction

1. This statement supersedes Statement of Practice SP5/80. Some features of the earlier statement have been omitted or revised but this does not indicate a more restrictive approach on the part of HM Revenue and Customs.

2. This statement gives general guidance on how HM Revenue and Customs interpret “arrangements” in the following provisions of ICTA 1988:

Section 240(11)(a) – surrender of Advance Corporation Tax to a subsidiary company;

Section 247(1A)(b) – group income elections in certain consortium cases;

Section 410(1) and (2) – group and consortium reliefs; and “option arrangements” in

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