Introduction Equity holders Overview Section 155: Arrangements for transfer of company owned by consortium etc
614.This section counteracts arrangements designed to obtain consortium relief. It is based on section 410 of ICTA.
615.It is possible to arrange for a loss-making company to become temporarily:
	a member of a consortium; or
	owned by a consortium
while the economic reality is that it is neither of these things. The section operates as soon as arrangements are made for the ownership of the company to change.
616.Subsection (1) appliesthe section potentially to any case involving a trading company and a consortium.
617.Subsection (2) denies group relief (by treating the trading company as not owned by a consortium) if “arrangements” are in place.
618.Subsection (3) sets out the four “effects” which bring arrangements within the section. They all involve a change in the control of the trading company or of a trade that it carries on.
619.Subsection (5) extends the operation of the section to cases where the trading company is owned indirectly by a consortium.