Market leading insight for tax experts
View online issue

Consortium relief and disqualifying arrangements

Speed read

There are some serious deficiencies in the present rules in relation to arrangements which preclude the surrender of consortium relief in certain circumstances. The problems have been exacerbated by the enactment of the previous extra-statutory concession, following the decision in Wilkinson. These problems include the absence of a safe harbour for the suspension of directors’ voting rights or for dilutions which take place through an issue of shares, instead of a transfer of shares. Another problem is that the legislation implies that the disqualifying contingencies include circumstances which are both unlikely to occur and undesirable. It is time for these provisions to be re-examined.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.