Commentary

D2.107 Definition of a group—meaning of body corporate

Corporate tax
Corporate tax | Commentary

D2.107 Definition of a group—meaning of body corporate

Corporate tax | Commentary

D2.107 Definition of a group—meaning of body corporate

The application of the group provisions are specifically restricted to only include a body corporate.

The reason for this restriction is because a company is defined1 as including any body corporate or unincorporated association (but not a partnership, a local authority or a local authority association) and the group provisions are not intended to extend to unincorporated associations.

Equally, indirect holdings in a body corporate held through an unincorporated association are ignored in ascertaining whether one body corporate is a subsidiary of another.

The term 'body corporate' is not defined in UK tax

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