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Contents

Official guidance
Corporate Intangibles Research and Development Manual

CIRD40000 · Intangible assets: groups

  • CIRD40010 · Overview
  • CIRD40020 · Significance of
  • CIRD40030 · Definitional rules
  • CIRD40035 · Example of subsidiary tests
  • CIRD40040 · Company cannot belong to more then one group
  • CIRD40045 · Principal company
  • CIRD40050 · Continuity: take-over or winding up
  1. Intangible assets: groups: contents
  2. Intangible assets: groups: principal company

CIRD40045 | Intangible assets: groups: principal company

From HM Revenue & Customs · Corporate Intangibles Research and Development Manual

CTA09/S767

A company cannot be the principal company of a group if it is itself a 75% subsidiary of another company. However, there is an exception where company B is a 75% subsidiary of company A, but not an effective 51% subsidiary of company A. In such circumstances company B may be the principal company of a group.

So, in relation to a group headed by company A there may be companies which satisfy the 75% subsidiary requirement in terms of ordinary share capital but which are not members of the A group because they are not effective 51% subsidiaries of A. In such cases you will need to determine which of these companies is capable of being the principal company of a lower tier group.

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