A popular area on groups which tax examiners love is the targeted anti-avoidance rules (TAAR) to prevent companies buying other companies to use up their pre-acquisition losses.
Blue Plc buys Orange Plc. Orange has pre-acquisition losses.
TAAR prevents Orange property and intangible losses from being refreshed.
If there is a major change in nature or conduct of trade (MCINOCOT) in Orange within a period of 5 years, then the pre-acquisition trading losses cannot be carried forward to the period of new ownership.
Companies in the Blue Plc group cannot access any of Blue Plc’s pre-acquisition capital losses.
Hope your revision is going well. If you need my condensed notes which makes it simple to learn the technical rules, you can purchase them using the link below: