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Corporation Tax Act 2010

Consortiums

336.If the shares in a single company (C) are held by other companies (M1, M2 etc), C may be a “company owned by a consortium”. In that case, losses of C may be set off against the profits of M1, M2 etc. And the losses of M1, M2 etc may be set off against the profits of C.

337.If C is also a member of a group (with its subsidiary S) it may be possible for losses to flow between members of the group and M1, M2 etc. And if M1 is a member of a group (with its parent P) it may be possible for losses to flow between members of that group and C.

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