75 per cent subsidiary, meaning

Accounting practices

Acquisition of a holding in a subsidiary

Advance corporation tax set-off


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


Assets held on 31 March 1982

Assets held on 6 April 1965, election by principal company

Avoidance scheme

Beneficial ownership, meaning



Sale of shares

Business property relief

Buying losses and gains, restrictions



Pre-change assets

Qualifying change of ownership

Tax advantage, meaning

Capital goods scheme

Chargeable gains

Allowable loss in respect of disposal or share exchange

Assets held at March 1982 or April 1965

Company, meaning


Debts transferred between



Enterprise investment scheme deferral of capital gains

European company (SE)


Global groups

Group remaining same group

Identification of groups

Indexation allowance

Indexation, intra-group transfers

Intra-group transfers

Investment trusts, intra-group transfers

Liquidations etc.


– see Loans

Meaning of group

Membership of more than one group, tie-breaker rules


No gain/no loss provisions, intra-group transfers

No gain/no loss transfer, disposal of asset after

Non-resident groups

Pre-entry gains and losses


Reallocation of gain or loss accruing

Recovery of tax

Replacement of business assets

Roll-over relief

Share exchange treated as disposal

Substantial shareholdings, transfer of trading assets within group

Trading stock treatment

Value of guarantees

Value shifting

Close companies, transfers

Company share option plans

Construction industry scheme

Continuous supplies of goods or services, tax point

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


Intangible fixed assets


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


Assignment between members

Between associated companies, interest payable

– see Interest

Deemed contractors

Default surcharge


51 per cent subsidiary, ceasing to be

Associated companies

Claim to reduce charge



Events resulting in

FA2011 mechanism


Intangible fixed assets


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


– see also Demergers


Depreciatory transactions

Derivative contracts

– see also Derivative contracts


Different accounting practices

Disposals or acquisitions outside group


– see 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

Eligibility for group treatment

Employee share ownership plans

Employee share schemes

Enterprise investment scheme relief

European Company (SE), becoming

Exclusions from DR charge (“relevant shares”)

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


Going concern purchases

Group income

– see 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

– see also Group relief


Mutual societies, transfers of business



Group relief claims

Group relief – loan relationship

Group treatment

Group, meaning

Incorporated friendly societies

Information and inspection powers

Insurance companies

Meaning of group

Non-statutory arrangements

Transfers of business

Intangible fixed assets

Degrouping charge




Related parties test

Roll-over relief

Transfers within a group

Inter-group transfers


Non-resident trusts

Original market value and aggregate market value

Intra-group income

Trustee savings banks

Intra-group interest

Intra-group share exchange

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

– see also Loan relationships

Financing costs and income

Intra-group transactions

Loan relationships, novation of liabilities


Depreciatory transactions

Dividend stripping

Land with development value

Loans to traders

Mineral leases

Oil field interests

Pre-entry losses

Schedule D, Case VII

Share loss relief


Value shifting

Main case gateway

Management charges

Management expenses

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



Novation of swaps between, avoidance of tax

Option arrangements

Ordinary share capital, meaning

Parent companies and subsidiaries, EU directive

Partial exemption

Patents, profits from exploitation

– see Patents

Payment of tax arrangements

Payments for group relief, consideration

Payments of tax, arrangements on behalf of group members

Pre-acquisition inducements

Pre-entry gains and losses

Pre-entry losses


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


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


Reinvestment relief

Relevant third person


– see Group relief

Reliefs available

Group relief

– see Group relief

Replacement of business assets

– see also Roll-over relief


Oil fields

Replacement of business assets, qualifying conditions

Representative member


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


Construction services

Motor cars

– see Self-supplies

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

Special rules


Inter-group staff charges

Joint employment contracts


Subsidiary, meaning

Substantial shareholdings exemption

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

Time limits for elections and claims

Tonnage tax

– see 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


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 shifting

Venture capital trusts, intra-group transfers


Worldwide debt cap

Worldwide groups financing costs and income