Group gains ― summary of relevant issues

Produced by Tolley

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Group gains ― summary of relevant issues
  • Implications of group membership
  • Group anti-avoidance provisions

Group gains ― summary of relevant issues

Companies form a capital gains group when one company (the ‘principal company’) owns at least 75% of the ordinary shares of one or more other companies. Sub-subsidiaries are also included where the direct relationship involves at least 75% share ownership and the indirect relationship to the principal company involves share ownership above 50%. A company can only be a member of one group. This definition is slightly different to the rules for group relief.

See the Group gains guidance note for further details on the definition of a group for gains purposes.


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