Taxation of Chargeable Gains Act 1992 section 285A

European Economic Interest Groupings

Section 285A sets out the capital gains tax rules that apply to UK Economic Interest Groupings and European Economic Interest Groupings, treating them as transparent entities whose assets and activities are attributed directly to their members.

• A grouping is not taxed as a separate entity — it is treated as an agent of its members, with its activities regarded as those of its members acting jointly, similar to a partnership.
• Each member is treated as owning a share of the grouping's property, rights and liabilities, and any trade or profession carried on by the grouping is treated as carried on in partnership by the members.
• A member is regarded as acquiring or disposing of a share of the grouping's assets not only when the grouping itself buys or sells assets, but also when the member joins, leaves, or experiences a change in their share of the grouping's property.
• A member's share is determined first by the grouping's formation contract, then by reference to profit-sharing entitlements under that contract, and if neither is specified, all members are treated as having equal shares.