The companies which make a ‘pooling election’ form an NRCGT group.

(TCGA 1992, s. 188B(1))

Such an ‘NRCGT group’ may be (though does not have to be) part of - so a ‘sub-set’ of - a wider group of companies (within the meaning of TCGA 1992, s. 170).

Pooling election

A pooling election is an election which:

(1)specifies the date from which the election is to have effect (the ‘effective date’ of the election), and

(2)is made by all those members of a group which are qualifying members.

The election cannot specify an effective date earlier than 30 days before it is made. An election is irrevocable.

(TCGA 1992, s. 188A(1),(5),(6))

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