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Groups within company structures

12 September 2017 / Jonathan Coletta ACA, CTA
Issue: 4615 / Categories: Comment & Analysis

Let’s form a group


  • Understanding the relationships of companies within a group is important to maximising exam marks.
  • Understanding whether companies are related will enable the corporation tax payment dates to be determined.
  • Companies owning at least 75% of others can surrender certain losses within the group.
  • Consortium companies can also surrender losses but restrictions apply.
  • For a gains group a company must be an immediate 75% subsidiary but the effective interest can be less.

Groups are an important part of ATT Paper 4. In fact although I am not on intimate terms with the examiners I would say that a long question from them is almost guaranteed in the real exam not to mention short form questions (SFQs). Unless students are prepared to forfeit 20 or more...

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