The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
This guidance note is intended to cover the main strategies that a group of companies should consider in advance of the year end. The strategies outlined are aimed at reducing the group’s overall liability to corporation tax and other costs by:
ensuring that losses within a group are relieved as quickly as possible
reducing the compliance burden on the group overall, resulting in both time and cost savings
This note should be read in conjunction with the following notes:
Introduction to year-end tax planning
Chargeable gains planning
Year end tax planning ― international issues
See also Checklist ― year-end tax planning for businesses for more information.
For the definition of a group company, see the definition of group for group relief purposes in the Group relief guidance note.
Subject to commercial and legal considerations, large groups of companies should consider whether a reduction in the number of distinct corporate entities would reduce professional, legal and other costs without interfering with operational efficiency.
Merging corporate entities to form a single company or a smaller group of companies may reduce overall group overheads.
The most common way that a merger is achieved is by transferring the trade of one company to another company, leaving the first company dormant. The dormant company is then struck off the register.
For more information on the transfers of the trade and assets between 75% group members, see the Transfer of a trade guidance note.
See also the Reconstructions involving transfer of business guidance note.
For the VAT considerations of transferring a trade to a group member, see the TOGC ― other related issues guidance note.
The EU Mergers Directive 2009/133/EC facilitates tax neutrality in cases where the parts of the business that are being merged are incorporated in at least two different member states. It has been incorporated into UK legislation at TCGA 1992, ss 140C–140L.
Where the conditions are satisfied, any such transfers of assets connected with the transfer of trade may take place on a
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
IntroductionSubsistence is the amount incurred as a consequence of business travel. Typically it relates to accommodation and meal costs incurred. These amounts are allowed because they are associated with the necessary travel. See the Travel expenses guidance note for more information of when
This guidance note explains the general rules surrounding the availability of indexation allowance on the disposal of company assets and provides information on the rebasing rules for assets held on 31 March 1982. For an overview of the general position regarding company disposals, please refer to
Maintenance payments are payments made by a taxpayer to their former or separated spouse for the maintenance of that former spouse or their children. To obtain any tax relief for maintenance payments, one of the couple must have been born before 5 April 1935 and the payments must be made by virtue
The corporate interest restriction (CIR) essentially limits the amount of interest expense a company can deduct from its taxable profits if the interest expense is over £2 million. The actual mechanics of the CIR calculation are highly complex (the legislation is over 150 pages long) and are
To view our latest tax guidance content, sign in to Tolley Guidance or register for a free trial.