CTM80180 - Groups: group relief: definitions of third company and successor

ICTA88/S410 (1)

The meanings of 'third company' and 'successor' for the purposes of arrangements, which disqualify group relief ( CTM80175), are set out below.

Third company

This means a company which, ignoring the effect of any arrangements such as are described in CTM80175 is not a member of the same group as the company in ICTA88/S410 (1)(b) to which the arrangements refer.

Successor

One company is a successor of another if it carries on, in whole or in part, a trade which the other company has ceased to carry on in certain circumstances where a balancing charge would not be chargeable on the ceasing company. The circumstances are where:

  • ICTA88/S343 (company reconstructions without a change of ownership) applies to the two companies ( CTM06000 onwards), or
  • the two companies are connected within the meaning of ICTA88/S839 (CG14620).