Part 4: Income tax, corporation tax and capital gains tax Section 35: Group relief Background note
This measure takes effect for consortium claims to group relief in accounting periods beginning on or after 10 December 2014.
	For group relief to flow between a company owned by a consortium and a company in the same group as a member of the consortium, the current rules require that the link company be in the UK or the EEA, and where in the EEA but not the UK all intermediate companies between the claimant and surrendering companies must also be in the EEA. This creates a difference of treatment between UK link companies and those in the EEA or in other jurisdictions.
	This measure seeks to remove that difference in treatment and simplify claims to group relief between a consortium and a group owning a share in that consortium by omitting the additional conditions where the link company is based in a jurisdiction other than the UK.