Background Note
24.This new Part was announced for the first time at Budget 2015.
25.The government has introduced this anti-avoidance rule to counteract the advantage for companies of entering into contrived arrangements to circumvent:
the carry-forward rules for the relevant carried-forward reliefs, which limit the way in which relief can be given; and
the group relief rules in Part 5 of CTA 2010, which only allow relief to be surrendered by a group company against profits arising in the same overlapping period, and not the surrender of relief that has been carried-forward.
26.It is not intended to catch tax planning to make efficient use of relief available to companies within the group, and this is measured through the objective test in condition D in section 730G.
