Corporation Tax Act 2010 section 269ZZB

Meaning of "group"

Section 269ZZB defines what constitutes a "group" for the purposes of the corporate interest restriction rules on deductions allowance, using a 75% ownership threshold and extending the definition to cover entities without share capital.

• A group consists of an ultimate parent company and all its subsidiaries, where the ultimate parent is not itself a subsidiary of any other company in the group
• A company is a "parent" of another if it holds at least 75% of the subsidiary's shares, distributable profits, or assets available on winding up
• Special rules treat registered society share capital as ordinary share capital and disregard shares held as trading stock
• The definition extends beyond conventional corporate structures to cover companies without share capital, unincorporated associations, and ownership through entities, trusts, or other arrangements

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