Commentary

D2.249 Overview of the group relief anti-avoidance provisions

Corporate tax
Corporate tax | Commentary

D2.249 Overview of the group relief anti-avoidance provisions

Corporate tax | Commentary

Group relief—anti-avoidance

D2.249 Overview of the group relief anti-avoidance provisions

In broad terms, there are four main areas of anti-avoidance legislation affecting the availability of group relief. They are as follows:

  1.  

    (1)     provisions aimed at preventing the creation of artificial groups of companies by the manipulation of the classes and rights of share capital in such a way that group relief can be surrendered between companies having no real economic interest in each other (see D2.250)

  2.  

    (2)     provisions that apply where arrangements exist for the transfer of a company to another group. These are aimed at preventing the creation

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