What is the purpose of section 269ZVA of the Corporation Tax Act 2010?

Section 269ZVA allows the nominated company of a former group to continue submitting and managing group allowance allocation statements after the group has ceased to exist. This ensures the administrative process of allocating the group's deductions allowance can be completed even after the group breaks up for corporate interest restriction purposes.

When does section 269ZVA of the Corporation Tax Act 2010 apply?

Section 269ZVA applies where a group of companies ceases to be treated as a group because its members no longer satisfy the relevant grouping conditions, and a group allowance nomination was in effect immediately before the group ceased to exist. This includes nominations made retrospectively after the group broke up under the applicable rules.

Can the nominated company still submit allocation statements after the group ceases to exist?

Yes. Under section 269ZVA, the company that was the nominated company under the last group allowance nomination retains the ability to submit group allowance allocation statements and revised statements. The usual requirement that the company must be the nominated company of an existing group is disapplied, ensuring continuity of compliance.

How does section 269ZVA treat references to the listed ultimate parent of the group?

Where the rules refer to a listed company that is the ultimate parent of a group, section 269ZVA requires this to be read as referring to the listed company that held that position immediately before the group ceased to exist. This preserves the integrity of the allocation process and ensures proper compliance with corporate interest restriction rules.

Corporation Tax Act 2010 section 269ZVA

Group allowance allocation statement: former groups

Section 269ZVA allows the nominated company of a former group to continue submitting and managing group allowance allocation statements after the group has ceased to exist for corporation tax purposes.

This section applies where a group ceases to qualify as a group because its member companies no longer meet the relevant grouping conditions, and a group allowance nomination was in effect immediately before the group ceased to exist
The company that was the nominated company under the last group allowance nomination retains the ability to submit a group allowance allocation statement, even though the group no longer exists
For the purposes of submitting statements, revised statements, and meeting the relevant requirements, the former nominated company is treated as though it is still the current nominated company for the group
Where the rules refer to a listed company that is the ultimate parent of a group, this is read as referring to the listed company that was the ultimate parent immediately before the group ceased to exist

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.

Become a member