Corporation Tax Act 2010 section 279F

"Related 51% group company"

Section 279F defines what a "related 51% group company" is, which matters because the number of such companies determines how the upper and lower profit limits for the small profits rate of corporation tax are divided.

  • A company is a "related 51% group company" of another if one is a 51% subsidiary of the other, or both are 51% subsidiaries of the same parent company.
  • Where companies are related 51% group companies for only part of an accounting period, they still count for the purposes of dividing the profit limits.
  • Dormant companies — those with no active trade, investment business, or property business — are excluded from the count.
  • This definition replaced the previous "associated companies" rules that were formerly used to divide the profit limits.

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