Group relief

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VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Group relief content

Practice notes
Corporation tax group relief: claims procedure and paymentsConditions for claiming group reliefIf a company (the surrendering company) has a loss or...
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16th Sep
Q&As
Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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16th Aug
Practice notes
How much group relief can be surrendered and claimed?The maximum amount of group relief that a company (the claimant company) can claim in any given...
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15th Aug
Practice notes
Corporation tax loss relief for carried-forward lossesProvisions in the Finance (No 2) Act 2017 (F(No 2)A 2017) made considerable reforms to the rules...
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15th Aug
Practice notes
How much consortium relief can be surrendered and claimed?Consortium relief is the term used to describe an extension to the group relief rules that...
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15th Aug
Practice notes
Consortium reliefConsortium relief is an extension of the group relief rules to allow the surrender and claim of losses between companies that are not...
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15th Aug
Practice notes
Surrender of tax refunds within a groupA company within a group can, in certain circumstances surrender a tax refund which is due to it to another...
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15th Aug
Practice notes
Group relief—types of losses that can be surrenderedA company can surrender by way of group relief:•a trading loss•a capital allowance excess•a...
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15th Aug
Practice notes
Group relief—loss relief groupWhy does it matter?It is common for corporate entities to operate within a group, ie several companies under common...
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15th Aug
Practice notes
Priority between loss reliefs in loss making companiesWhy does it matter?A company that is a member of a group and has incurred any of the types of...
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15th Aug
Precedents
Group Relief AgreementThis Agreement is made on [insert date]Parties1[Insert name of party] a company incorporated in England and Wales (under number...
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15th Aug

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