52U.K.In section 127 “arrangements” covers only—
(a)arrangements made on or after 20 February 2006, or
(b)arrangements made before that date if—
(i)the amount (or part) would (apart from that section) first qualify for group relief on or after that date, or (as the case may be)
(ii)the amount (or part) arises on or after that date.