| Commentary

30.2 Corporation tax groups

| Commentary

30.2 Corporation tax groups

For the purposes of corporation tax groups, two companies are members of a group if one is the 75% subsidiary1 of the other, or both are 75% subsidiaries of a third company. The parent company must also be beneficially entitled to not less than 75% of any profits distributable to equity holders of the subsidiary company and 75% of any assets available for distributions to equity holders on a winding up. The group relief provisions, amongst other things, allow trading losses, losses from UK property business, management expenses, excess capital allowances and non-trading deficits

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