Corporation Tax Act 2010 section 709

Meaning of "the relevant period"

Section 709 defines "the relevant period" used throughout the chapter on change of company ownership, setting the window of time within which certain transactions may be scrutinised.

• The relevant period is generally the 3 years before a change in ownership of a company.
• If there was an earlier change in ownership within that 3-year window, the relevant period is shortened to the time between the earlier and later changes.
• This shortened period protects a previous owner who sold the company without tax avoidance intent from being caught by arrangements entered into by a subsequent owner.
• The effect is that each new owner is accountable only for what happens during their own period of ownership, not for a predecessor's actions.