SCHEDULE 11Reconstruction relief and acquisition relief

PART 4Withdrawal of relief

Withdrawal of relief on subsequent non-exempt transfer

I123

This paragraph applies where a company holding shares in the acquiring company to which the exempt intra-group transfer related, or that are derived from shares to which that transfer related, ceases to be a member of the same group as the target company—

a

before the end of the period of 3 years beginning with the effective date of the transaction which is exempt from charge by virtue of Part 2, or is subject to a reduced amount of tax by virtue of Part 3, of this schedule (“the relevant transaction”), or

b

in pursuance of, or in connection with, arrangements made before the end of that period.