Following the decision in Shepherd v Law Land plc 63TC692, a
consortium group relationship which would otherwise exist is only
broken by reason of ‘arrangements’ within ICTA88/S410
while those arrangements are in existence. A consortium group
relationship is not necessarily broken for the whole of an
accounting period during which Section 410 arrangements have
existed.
Where Section 410 arrangements interrupt an existing
consortium group arrangement during an accounting period, the
provisions of ICTA88/S403A apply (
CTM80210).
