KEY POINTS

A considerable number of reliefs apply to ‘groups’ of companies. Their purpose is, broadly, to ensure that where an economic entity carries on activities through more than one company, those companies are not put in a worse position from a tax perspective than if all the activities were carried on in a single company.

A ‘group’ is primarily ascertained by reference to common ownership of ordinary share capital (in particular with 75% and 51% thresholds). But the definition is more complex than this, and in fact varies depending upon the legislative provisions under consideration.

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