The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
The main implications of companies being grouped for capital gains purposes are:
There are similar rules relating to intangible fixed assets. There are also exemptions from both stamp duty and stamp duty land tax for transfers between group companies. Both of these sets of rules include provisions to claw back relief in certain circumstances.
Please note that changes were made to the corporate gains rules for groups of companies by Finance Act 2011 with effect from 19 July 2011. The measures introduced mainly aimed to simplify the tax treatment of chargeable gains for corporate groups, with changes to degrouping charges, SSE and the repeal of certain measures which were considered to be redundant.
See the Degrouping charges and How does SSE interact with other legislation? guidance notes for details of how the rules differ before and after 19 July 2011.
Companies are in the same capital gains group when one company owns at least 75% of the ordinary shares of another company or when two companies are 75% owned by the same parent.
This 75% definition is similar to the rules for group relief but for group gains purposes, 75% ownership relates to ordinary shares only and not
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