188体育

The percentages shown in this diagram indicate beneficial ownership of ordinary share capital and you should assume that the arrangements rules (CTA10/Ss146A, 146B, and 155) do not apply.

The votes and entitlement to profits and assets on winding up follow the shareholdings shown (see CTA10/Ss151(4) for Q, R, S, and T (CTM80535), and Ss143(3) and 144(3) for the ownership proportions of W, X, Y, and Z in H (CTM80540 and CTM80545)).

All parties have an accounting period of 12 months to 31 December 2011, and the percentages shown remain constant throughout the accounting period.

H, a holding company, has the following trading subsidiaries shown above: Q, R, S, and T..

W, X, Y, and a bank Z are members of the consortium. Bank Z holds the shares in H on trading account. Each of the four companies in the consortium has ample profits to absorb any relief surrendered by the holding company and its subsidiaries.

The accounts of the following companies for the 12 months to 31 December 2011 give results as follows.

Company	Description	Amount
H	excess management expenses	拢5,000
Q	trading losses	拢4,000
R	trading losses	拢6,000
S	trading losses	拢2,000
T	trading losses	拢1,000

All the companies, including Z, give consent to claims for consortium relief. The members of the consortium may then obtain consortium relief as follows.

W

Consortium relief	Amount
25% of H鈥檚 excess management expenses	拢1,250
25% of Q鈥檚 loss	拢1,000
25% of R鈥檚 loss	拢1,500
No relief in respect of S鈥檚 loss (see below)	NIL
25% of T鈥檚 loss	拢250
Consortium relief	拢4,000

X

Consortium relief	Amount
25% of H鈥檚 excess management expenses	拢1,250
25% of Q鈥檚 loss	拢1,000
25% of R鈥檚 loss	拢1,500
No relief in respect of S鈥檚 loss (see below)	NIL
25% of T鈥檚 loss	拢250
Consortium relief	拢4,000

Y

Consortium relief	Amount
25% of H鈥檚 excess management expenses	拢1,250
25% of Q鈥檚 loss	拢1,000
25% of R鈥檚 loss	拢1,500
No relief in respect of S鈥檚 loss (see below)	NIL
25% of T鈥檚 loss	拢250
Consortium relief	拢4,000

Under CTA10/S153(3) there is no relief due to any of the members of the consortium for S鈥檚 loss because S is not a 90% trading subsidiary of H (CTM80535).

Z is not entitled to any relief (CTA10/S132(4) - CTM80530) because a profit on the sale of the shares it holds in H would be a trading receipt.

Losses, etc, to carry forward

The balance of losses and other amounts not surrendered may be carried forward by each company as follows.

Description	Company H	Company Q	Company R	Company S	Company T
Excess management expenses	拢5,000	-	-	-	-
Trading losses	-	拢4,000	拢6,000	拢2,000	拢1,000
Less surrendered as group relief	拢3,750	拢3,000	拢4,500	-	拢750
Carried forward	拢1,250	拢1,000	拢1,500	拢2,000	拢250