Commentary

D2.105 General requirements to form a corporate group

Corporate tax
Corporate tax | Commentary

D2.105 General requirements to form a corporate group

Corporate tax | Commentary

Definition of a group

D2.105 General requirements to form a corporate group

In broad terms, a group consists of:

  1.  

    •     a parent company (sometimes referred to in the legislation as a principal company), and

  2.  

    •     one or more subsidiary companies (see D2.106)

The definition of a group varies depending on the specific area of corporate tax in question, with different levels of direct and indirect ownership often stipulated in the legislation.

However, the requirements can, broadly, be split according to those that require a company to be a 51%, 75% or a 90% subsidiary (see D2.106). For example, the definition

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