In the first in a series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) focus on the conditions for corporation tax loss relief via group relief.
Different approaches are taken to the concept of tax groupings with certain jurisdictions (such as Germany the USA and Netherlands) adopting a concept of fiscal unity whereby multiple companies are treated as a single entity. The UK’s approach however is generally to respect companies as independent entities and then allow certain tax treatments or overrides in scenarios where companies are members of a tax group (for example corporation tax group relief nil gain nil loss transfers of assets within chargeable gain group). There is no single definition of a group for UK tax purposes and instead whether a group exists must be tested based on the requirements in the area of legislation being considered. ...
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In the first in a series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) focus on the conditions for corporation tax loss relief via group relief.
Different approaches are taken to the concept of tax groupings with certain jurisdictions (such as Germany the USA and Netherlands) adopting a concept of fiscal unity whereby multiple companies are treated as a single entity. The UK’s approach however is generally to respect companies as independent entities and then allow certain tax treatments or overrides in scenarios where companies are members of a tax group (for example corporation tax group relief nil gain nil loss transfers of assets within chargeable gain group). There is no single definition of a group for UK tax purposes and instead whether a group exists must be tested based on the requirements in the area of legislation being considered. ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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