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Group intangible fixed assets

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Group intangible fixed assets

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
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Groups

There is specific legislation which deals with groups of companies and intangible fixed assets. This looks at:

  1. •

    definition of ‘group’

  2. •

    intra-group transfers

  3. •

    rollover relief between group companies

  4. •

    rollover relief on acquisition of a subsidiary

  5. •

    degrouping charges, including reallocation of the charge, allocation of rollover relief, and recovery from another group company or director

  6. •

    intra-group payments for reliefs

CTA 2009, ss 764–799

This guidance note covers the definition of ‘group’ and intra-group transfers. For further guidance on the other areas, see the following guidance notes:

  1. •

    Degrouping charges and elections ― IFAs

  2. •

    Rollover relief on IFAs

  3. •

    Reorganisations / reconstructions ― IFAs

Definition

The definition of a group follows the definition for capital gains purposes. A group is defined as:

  1. •

    a parent company and its 75% subsidiaries

  2. •

    75% subsidiaries of those subsidiaries, etc to include all subsidiaries which are ‘effective 51% subsidiaries’ of the parent company

There is no geographic restriction on the definition of a group, so

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