Corporation Tax Act 2010 section 606

Groups

Section 606 defines what constitutes a "group" of companies for the purposes of Part 13 of the Corporation Tax Act 2010, including which companies are included and excluded from a group.

• A group is formed by a principal company together with all its 75% subsidiaries, including subsidiaries of subsidiaries, creating a potentially extensive corporate structure
• Certain entities are excluded from group membership, including companies that are not effective 51% subsidiaries of the principal company and open-ended investment companies
• A company can only be a member of one group at a time, with any overlap resolved by reference to the capital gains tax grouping rules in section 170(6) of TCGA 1992
• The single-group membership rule is disapplied for Chapter 10 (joint ventures), so a company may simultaneously belong to a joint venture group and another group