Groups (4) Flashcards
Most important factor for loss and group relief?
The rate at which relief can be obtained
Why can group relief claims be restricted?
So that the surrendering company retains sufficient losses to bring its own augmented profits down to the lower limit
WHat does a group company consist of?
A parent company and its 75% subsidiaries, and also the 75% subsidiaries of their subsidiaries
What must the parent company need only have (group)
An effective interest of over 50% in any sub-subsidiary companies
Why can a company only be in one group?
For gains purposes
What happens with group companies and transferring assets?
They will transfer assets between themselves without incurring a chargeable gain or allowable loss
When can group companies make an election (capital gain)?
A capital gain or loss incurred by one company may be treated as arising in another company
What is treated as one for purposes of rollover relief
Members of a 75% group
Rollover relief and groups
One company sells a qualifying asset and another company buys an asset within the rollover relief qualifying time period
Advantage of gains group membership (capital losses)
Group’s capital losses can be better utilised
Advantage of gains group membership (rollover relief)
Rollover relief is available on a group wide basis
Advantage of gains group membership (transfer)
Gains can be moved to a company with insufficient profits to cover its QCD
Advantages of a capital gains election (no transfer)
By not having to actually transfer assets within a group means a saving in legal and administrative costs
Advantages of a capital gains election (capital gain)
Election can be made in respect of any part of a capital gain or capital loss
Purpose of a capital gains group election?
To deem any part of a current period gain/loss made by one group member to have been made by any other gains group member
