To avoid the abuse of group relief provisions by, in particular, the formation of temporary groups or consortia, no relief is given if, broadly, at the time the right to group relief arises there are in existence arrangements which, when put into effect, would not entitle the companies involved to obtain group relief.

The right to group relief is removed in such cases by treating the companies which are members of the same group or owned by a consortium as not being members of the group or belonging to the consortium.

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