Broadly, dual resident companies are companies that simultaneously satisfy the residence rules of the UK and another country. CTA10/S109 prevents certain dual resident companies from setting off their losses and other amounts (see CTM34600) by way of group relief.

In addition, the following provisions also restrict access to other types of relief normally available to group or associated companies

CTA10/S948 (continuation treatment of capital allowances on transfer of trade)

TCGA92/S171 (transfers within a group)

TCGA92/S175 (replacement of business assets within a group)

CAA01/S61 (item 2 of the Table) (disposal value: sale of plant and machinery at undervalue)

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

Existing subscriber? Log in

No subscription?

Contact us to discuss your requirements.