Introduction Overview Overview Section 959: Arrangements for transfer of relief
2863.This section sets out the sorts of arrangements to which the Chapter applies. It is based on section 116 of ICTA.
2864.Subsection (1) identifies four effects that the arrangements may have. Effects 1 and 2 correspond to paragraph (b) of section 116(1) of ICTA; Effects 3 and 4 correspond to paragraph (a) of section 116(1) of ICTA.
2865.Subsection (2) makes clear that the Chapter operates by reference to part of a company’s share of the firm’s profits or losses as it operates by reference to the whole of the profits or losses. So the Act does not reproduce from section 116(1) of ICTA “any portion of” any of the profits or losses.
2866.Subsection (4) is the rule that a payment for group relief (see also section 183) does not trigger the anti-avoidance rules in this Chapter.