Corporation Tax Act 2010 section 990

UK Economic Interest Groupings and European Economic Interest Groupings

Section 990 sets out the basic rules for how corporation tax is charged on the members of UK Economic Interest Groupings and European Economic Interest Groupings (EEIGs).

  • A grouping acts as the agent of its members, and its activities are treated as those of the members acting jointly.
  • Each member is treated as holding a share of the grouping's property, rights and liabilities, and any trade carried on by the grouping is treated as a partnership of its members.
  • A member's share is determined first by the grouping contract, then by profit entitlement, and failing both, members are treated as having equal shares.
  • The loan relationships rules in Part 5 of CTA 2009 apply to a grouping in the same way as they apply to a firm, including provisions on partnerships involving companies and the meaning of "control" and "major interest".

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