Paragraph 19 Exemption for certain group transactions
United Kingdom
A company is not required by paragraph 8(2) to notify HMRC about an uncertain amount included in a relevant return if—
(a)
the relevant tax for the purposes of which the amount is brought into account is corporation tax,
(b)
the amount relates to a transaction between the company and one or more other companies at a time when all of the companies are members of the same group (see paragraph 3), and
(c)
the net effect of the transaction is that the value of the tax advantages (if any) that would be obtained by the group, taken as a whole, does not exceed the sum for the time being specified in paragraph 11(2)(b).