Corporation Tax Act 2010 section 152

Groups of companies

Section 152 defines when two companies are treated as members of the same group of companies for the purposes of group relief.

  • Two companies belong to the same group if one is a 75% subsidiary of the other
  • Two companies also belong to the same group if both are 75% subsidiaries of a third company
  • Securitisation companies and insurance securitisation companies are excluded from group membership by separate regulations
  • Similar exclusions for property securitisation companies have also been proposed

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