Groups Flashcards
Two types of groups
Group relief group (75% ownership and 75% effective interest)
Chargeable gains group (75% ownership and >50% effective interest)
Group relief
Surrender losses to minimise group CT
75% ownership and effective interest (subs of subs where 75% effective interest)
Losses surrendered between UK resident companies only (a foreign company can be within the link)
Joiners (when they have joined the group), Leavers (when final plans to leave) time apportion for this
Group relief - current period
Can transfer any amount of current period: trading losses, excess QCDs and property losses. Gets claimed against TTP (bottom line taxable figure after all deductions)
Don’t have to do a CY claim before transferring to other company
Group relief - carry forward
Any excess trading losses and property losses after the claimant company use its own current year and b/f losses
Chargeable gains groups
75% direct ownership and >50% effective interest in their subs
Automatic NIL gain NIL loss of transfer of assets (transfer at base cost)
Can elect any external disposals to be ‘from’ any member of the group to maximise capital gains/losses
One unit for rollover relief