Group gains ― summary of relevant issues

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

This note highlights the main issues to consider for companies which are members of a capital gains group as opposed to being a standalone company. See the Corporate capital gains ― overview guidance note for a general overview of corporate chargeable gains.

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.

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