½Û×ÓÊÓƵ

The relationship between a company owned by a consortium (a consortium company, C Ltd) and a member of the consortium (M Ltd) does not constitute control¹ and so does not in itself cause the two companies to be connected parties so as to refuse relief for impairment losses. (For the meaning of a consortium company and a member of a consortium, see D2.207A.)

However, where relief for trading losses is surrendered by one such company to the other (consortium relief, see D2.230), there may be a restriction of either the relief available in respect of impairment losses (previously, bad debts) or consortium relief in the circumstances described in 1–4 below².

The rules apply³:

1. Ìý

   •ÌýÌýÌýÌý where a debit for an impairment loss or the release by the lender of all or part of an amount is due under the terms of a loan relationship has been brought into account by M Ltd or by a company (G Ltd) which is a member of the same group as M Ltd and