Basics of group relief: Part 2

In the first article in this series ‘Basics of group relief: Part 1’ Taxation 25 January 2024 I covered the very basic aspects of group relief.

This second article looks at consortium relief the effect of payment for group relief and some common anti-avoidance.

Consortium relief

A consortium is formed where a company (the consortium company) is 75% or more owned by corporates (the consortium members) each of which owns at least 5% of the shares but none of which own 75% or more. It should be noted that consortium members do not need to be UK tax resident in order for a consortium to exist so if UK company A owns 10% of UK company B and 70% of B is owned by a non-UK company then A and B are in a consortium.

Consortium relief is available only between the...