Commentary

D2.264 Group relief—dual resident investing companies

Corporate tax
Corporate tax | Commentary

D2.264 Group relief—dual resident investing companies

Corporate tax | Commentary

D2.264 Group relief—dual resident investing companies

Specific provisions prevent a company surrendering losses by way of group relief, consortium relief or group relief for carried forward losses if during the period in which the loss is incurred it is a dual resident investing company1.

The determination of the residence of a company is described in D4.109. Where different countries have different tests for determining whether a company is resident it is possible for a company to be resident in more than one country. This is often the case where a company is resident in the UK simply because it is incorporated

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