A company could not validly surrender group relief as it had ceased to be a member of the same group as the claimant company for group relief purposes upon the appointment of receivers of the surrendering company. 
 
The appellant companies (‘Farnborough’) appealed against decisions by HM Revenue and Customs (HMRC) to disallow Farnborough’s claims for group relief (under CTA 2010, s 154) of some £10.5 million surrendered by Piccadilly Hotels 2 Limited (PH2L) in respect of PH2L’s accounting periods ended 31 January 2012 and 2013. The losses were claimed in Farnborough’s accounting periods ended 31 May 2012. Farnborough and PH2L were both at least 75% subsidiaries of another company (KL) for the purposes of CTA 2010, s 152. 
 
HMRC’s disallowance of the group relief claim was because PH2L was placed into receivership on 27 June 2011. HMRC argued that the appointment