CTM80185 - Groups: group relief: enabling arrangements
‘Enabling’ arrangements (CTM80175) are usually (though not invariably) in written form and binding on the parties.
It may be stipulated that they are not operable until a specific date after the end of the accounting period to which the group relief claim relates. Such arrangements are nevertheless in existence, and so may disqualify group relief. This follows from the words ‘or after the expiry of that accounting period’ in ICTA88/S410 (1)(b).