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Group relief​

 

No longer available after appointment

"[70] For these reasons, therefore, I conclude that the effect of the appointment of the receivers was indeed to deprive Kelucia (and the intermediate companies in the corporate chain) of their shareholder control of PH2L. It follows that the requirements of Effect 2 were satisfied." (Farnborough Airport Properties Company v. HMRC [2019] EWCA Civ 118)

Legislation: 

Cases: 

HMRC manuals: 

Commentary: 

See also:

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 © 2023 by Michael Firth, Gray's Inn Tax Chambers

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