Groups of companies
51 per cent subsidiary
75 per cent subsidiary
75 per cent subsidiary, meaning
Accounting for VAT
Accounting practices
Acquisition of a holding in a subsidiary
Acquisitions of business by a group, self-supply
Advance corporation tax set-off
Anti-avoidance
Anti-avoidance provisions
Assessment in consequence of direction
Form of directions
Manner of giving directions
Power to give directions
Restrictions on giving directions
Time limit on directions
Application for group treatment
Arrangements
Arrangements, payment of corporation tax
Assets held on 31 March 1982
Assets held on 6 April 1965, election by principal company
Avoidance scheme
Bad debt relief
Former members, clawback of refund
Generally
Basis of taxation
Beneficial ownership, meaning
Generally
Liquidation
Sale of shares
Business property relief
Buying losses and gains, restrictions
Gains
Losses
Pre-change assets
Qualifying change of ownership
Tax advantage, meaning
Capital goods scheme
Changes, planning
Chargeable gains
Allowable loss in respect of disposal or share exchange
Assets held at March 1982 or April 1965
Company, meaning
De-grouping
Debts transferred between
Degrouping
Degrouping charges
Demergers
Enterprise investment scheme deferral of capital gains
European company (SE)
Failure to pay tax on, recovery within group
Generally
Global groups
Group remaining same group
Identification of groups
Indexation allowance
Indexation, intra-group transfers
Intra-group transfers
Investment trusts, intra-group transfers
Linked company debts and shares
Liquidations etc.
Loans
Meaning of group
Member leaving group
Membership of more than one group, tie-breaker rules
Mergers
Mergers, consequences of
No gain/no loss provisions, intra-group transfers
No gain/no loss transfer, disposal of asset after
Non-resident groups
Non-UK residents
Notional transfers within a group, pre-21 July 2009
Pre-entry gains and losses
Re-basing
Reallocation of gain or loss accruing
Recovery of tax
Recovery of tax within group
Replacement of business assets
Roll-over relief
Share exchange treated as disposal
Substantial shareholdings, transfer of trading assets within group
Surrender of tax refund within group
Trading stock treatment
Trading stock, acquisition or disposal within group
Transfer of assets between members
Transfer of gains and losses within group
Value of guarantees
Value shifting
Close companies, transfers
Company share option plans
Construction industry scheme
Continuous supplies of goods or services, tax point
Corporation tax payments
De-grouping charges
Associated companies
Chargeable asset
Claim for a reduction
Conditions no longer met
Deemed sale etc.
Deferral until company leaves new group
Disposal of shares
European Company (SE) formation by merger
Generally
Intangible fixed assets
Mergers
Post-appointed day cases
Pre-appointed day cases
Reallocation within group of gain or loss
Roll-over relief
Substantial shareholdings exemption
Time-limit for valuation
Two companies leaving the group together
Debt capping rules
Debts
Assignment between members
Between associated companies, interest payable
Deemed contractors
Default surcharge
Definition
Degrouping
51 per cent subsidiary, ceasing to be
Associated companies
Claim to reduce charge
Demergers
Dissolution
Events resulting in
FA2011 mechanism
Generally
Intangible fixed assets
Loan relationships
Mergers
Nature of charge
Ownership of asset/replacements
Post-19 July 2011
Reallocation of gain or loss accruing
Roll-over relief pre-19 July 2011
Sub-group exemption
Substantial shareholdings
Value shifting
Demergers
Generally
Depreciatory transactions
Derivative contracts
Generally
Different accounting practices
Disposals or acquisitions outside group
Distributions
Distributions, members of a 90 per cent group
Dividend stripping
Double taxation relief, surrender of unrelieved foreign tax
Dual resident investing companies
EC parent/subsidiary directive
Effect of supplier leaving VAT group
Eligibility for group treatment
Employee share ownership plans
Employee share schemes
Enterprise investment scheme relief
EU sales list
European Company (SE), becoming
Exit charge
Associated companies
Principal company becoming non-resident
Finance leases
Financing costs and income
Franked investment income group litigation order, interim repayment payment order
General provisions
Generally
Going concern purchases
Group ceasing to exist
Group income
Group income election
Advance corporation tax, restitutionary claim where payment made under mistake of law
Restriction, EU law
Group litigation order, interim repayment payment order
Group mismatch schemes
Group relief
Amounts available for
Application of
Arrangements to transfer relief, loss of
Charitable donations
Connected persons
Consortium relief
Corporation tax self-assessment
Dual resident companies
Equity holder
Example
Foreign and non-commercial trades
Generally
Holding company
Loan creditor
Loss of where arrangements in existence
Management expenses
Member of a consortium
Member of group and a consortium
Mutual societies, transfers of business
Nature of
Non-resident companies
Normal commercial loan
Ownership proportion
Partnerships
Property business losses
Quoted unconnected company
Restricted preference shares
Set-off
Stamp duty land tax
Time-limits for claims
Value added tax
Withdrawal
Group relief, time limits for elections and claims
Group treatment
Group, meaning
Incorporated friendly societies
Information and inspection powers
Insurance companies
Meaning of group
Non-statutory arrangements
Transfers of business
Insurance premium tax
Intangible fixed assets
Degrouping charge
Generally
Liquidation
Meanings
Mergers
Related parties test
Roll-over relief
Transfers within a group
Inter-group transfers
Generally
Non-resident trusts
Original market value and aggregate market value
Intra-group income
Trustee savings banks
Intra-group interest
Intra-group share exchange
Intrastat, responsibility for submission
Investment trusts, transfer of assets within a group
Issued share capital, meaning
Joint venture companies
Substantial shareholdings exemption
Transfer of shares or securities/suspension of member's voting rights
Liability for group treatment
Liability for returns
Limitation on holdings in resident companies
Loan agreement on terms that shares are paid to a different group company
Loan relationships
Degrouping
Financing costs and income
Intra-group transactions
Mismatch rules
Loan relationships, novation of liabilities
Losses
Depreciatory transactions
Dividend stripping
Land with development value
Loans to traders
Mineral leases
Non-resident companies
Oil field interests
Pre-entry losses
Schedule D, Case VII
Share loss relief
Transfers
Value shifting
Management charges
Management services
Continuous supply, re-attribution of input tax
Identification of recipient
Member states freedom of establishment
Modification of group treatment
Mortgage of shares or securities
Non-resident companies
Attribution of gains to shareholders
Generally
Non-residents
Notifications
Novation of swaps between, avoidance of tax
Option arrangements
Ordinary share capital, meaning
Overlapping period
Ownership of ordinary share capital
Parent companies and subsidiaries, EU directive
Partial exemption
Patents, profits from exploitation
Payment of tax arrangements
Payments for group relief, consideration
Payments of tax, arrangements on behalf of group members
Pre-entry gains and losses
Pre-entry losses
Application
Appropriations to stock in trade
Change of company's nature
Companies changing groups on certain transfers of shares etc.
Continuity provisions
Contract for sale of losses
Gains from which deductible
General provisions
Generally
Relevant event
Restrictions on deduction
Set-off against chargeable gains
Transitional provisions
Principal company of the group, meaning
Profits, meaning
Property rental business
Quoted securities
Real estate investment trusts
Recovery of tax
Recovery of tax from another group or controlling director
Registration
Reinvestment relief
Relief
Reliefs available
Group relief
Replacement of business assets
Generally
Oil fields
Replacement of business assets, qualifying conditions
Representative member
Residence
Restructuring and rationalisation, transfer of losses for valid commercial reasons
Reverse charge: value of group supplies using overseas member
Ring fence trade
Reinvestment relief, acquisition by member of same group
Transfers within groups of companies
Road fuel provided by group member to individual
Self-supply
Construction services
Motor cars
Share loss relief
Shares and securities
Beneficial ownership, meaning
Delaware limited liability companies
Elections to include 1965 quoted shares with 1982 holding
Issued share capital, meaning
Non-UK entities
Ordinary share capital, meaning
Share ownership, determination of extent
Staff
Inter-group staff charges
Joint employment contracts
Stamp duty land tax
Subsidiaries
Subsidiary, meaning
Substantial shareholdings exemption
Surrender of company tax refund, time limits
Surrender of tax refund within group
Effects of surrender
Interest on tax overpaid/underpaid
Payments for
Power to surrender tax refund
Taxation as, freedom of establishment
Termination of group treatment
Tonnage tax
Trade, meaning
Trading stock, loss on sale of transferred properties
Transaction in securities, reconstructions/reorganisations
Transfer pricing
Transfer within group
Application to intra-group disposal
Tax avoidance
Transfers
Goods and services: payments received for non-supplies
Property rental business as a going concern
Transfers of property, relief
Transfers within
Transfers within a group
Election to reallocate gain or loss to another group member
General provisions
Investment trusts
Shares in exchange for qualifying corporate bonds
Trading stock
Venture capital trusts
Underlying tax on dividends, taxed as single entity
Unpaid tax, recovery of
Unrelieved surplus ACT
Value added tax, registration
Value shifting
Venture capital trusts, intra-group transfers
Verification
Worldwide debt cap
Worldwide groups financing costs and income
