Module 17: Group Companies Flashcards
51% group companies dividends received
Ignored when calculating augmented profits
51% group companies AIA
Single AIA shared between group companies
Company giving yo loss
Surrendering company
Recipient company
Claimant company
Losses carried back
Cannot be surrendered by surrendering company
Claimant company group relief tax comp
Last relief in comp therefore after c/f losses, CY losses, QCDs
When company joins/ leaves during accounting period
Profits/ losses are time apportioned
UK losses to foreign subsid
Cannot be surrendered
Overseas losses can be surrendered to UK if (2)
- resident in EEA
- foreign tax loss cannot be received in home state
Claim for group relief requires
Consent of surrendering company
Group relief claim included in
Company’s tax return
Pre-entry capital losses limits (2)
Set against
- gains on assets held by company at time it joined group
- gains on assets bought from non group companies after joining group
Company joins group - limit on trading losses carried forward
5 years
Sale from substantial shareholding
Exempts gain for disposal of shares of 10% or more held for 12 months not more than 6 years before disposal
To allow restructure/ reorganisation without tax consequences
Transfer pricing requires
Certain companies to prepare self-assessed corporation tax returns with transaction price replaced with arm’s length price
