SCHEDULE 10Group relief

F1PART 3ARecovery of relief

42B

The following persons may, by notice under paragraph 42E, be required to pay the unpaid tax—

(a)

the seller,

(b)

any company that at any relevant time was a member of the same group as the buyer and was above it in the group structure,

(c)

any person who at any relevant time was a controlling director of the buyer or a company having control of the buyer.