SCHEDULE 10Group relief
PART 3Withdrawal of relief
Amount of tax chargeable where relief partially withdrawn
18
Where relief is partially withdrawn, the amount of tax chargeable is an appropriate proportion of the amount determined in accordance with paragraph 17.
19
An “appropriate proportion” means an appropriate proportion having regard to—
(a)
the subject-matter of the relevant transaction, and
(b)
what is held at the relevant time by the buyer or, as the case may be, by the buyer and its relevant associated companies.