What’s happened to the proposed consortium relief link company provisions?

The original draft of the Finance Bill 2015 published on 10 December 2014 included legislation that proposed amendments to the consortium relief tax loss surrender rules in relation to what are known as ‘link companies’. These provisions were not included in the final draft of the Finance Bill 2015 and are therefore not included in FA 2015.

A ‘link company’ is a company that is a member of a consortium and also a member of a group relief group. As the name suggests this company can act as a link between a consortium company (and its group) and the wider group relief group of the consortium member allowing tax losses to be surrendered between the consortium company (and its group) and the linked group of the consortium member. Under current legislation such surrenders are...