HMRC may enter into arrangements with some or all of the members of a group of companies to allow one member to discharge the corporation tax liabilities of the group.

(TMA 1970, s. 59F(1),(2))

‘Group’ for these purposes means a company and all of its 51 per cent subsidiaries, any 51 per cent subsidiaries of those subsidiaries, and so on. Any such payment does not have to be broken down between the respective group members at the time of payment, but will be allocated to them as their tax liabilities arise under self-assessment.

(TMA 1970, s. 59F(3))

The arrangements may extend also to:

(1)amounts due under CTA 2010, s. 455 or s. 464A (loans or benefits to participators),

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