D1.645 Corporate intangibles in groups—overview
The corporate intangible regime includes self-contained provisions relating to groups of companies.
The group provision commentary is summarised as follows:
| Summary | Link |
| Definition of a group | Below |
| Transfers of an intangible asset within a group | D1.646 |
| Intangible assets—rollover relief and groups | D1.647 |
| Intangible assets—degrouping charges | D1.649 |
| Intangible assets—exemptions from the degrouping charge | D1.650 |
| Intangible assets—reallocation of degrouping charge within group | D1.652 |
| Intangible assets degrouping charge—recovery of tax | D1.653 |
| Intangible assets—payments between group members for reliefs | D1.654 |
Definition of a company and a group
The definition of a group is set out within the corporate intangible regime but follows the definition for capital gains provisions (see D2.305). A group includes the principal company and companies which are its 75% subsidiaries. If any of those subsidiaries themselves have 75% subsidiaries, they too are included in the group, and so on1. The meaning of 75% subsidiaries is a holding of 75% of the ordinary share capital either directly or indirectly2.
For
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 13:22