Corporation Tax Act 2009 section 765

General rule: a company and its 75% subsidiaries form a group

Section 765 sets out the basic rule for determining which companies form a group for the purposes of the intangible fixed assets regime.

  • A company and all its 75% subsidiaries form a group for intangible fixed assets purposes.
  • The group extends downwards to include 75% subsidiaries of those subsidiaries, and so on through further tiers of ownership.
  • The top company in the group is known as the principal company of the group.
  • This general rule is subject to further provisions in the same chapter that may modify or restrict group membership.

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