CIRD40020 - Intangible assets: groups:
significance of
Why does it matter if there is a group relationship?
Whether there is a group relationship affects a number of other
provisions. In particular:
- transfers of chargeable intangible assets
(
CIRD20035) between group members
generally take place on a tax-neutral basis (
CIRD40200),
- as a consequence there is a
‘degrouping’ adjustment on a company leaving a group
while holding an asset that has been transferred to it on
tax-neutral terms (
CIRD40500),
- a taxable credit on degrouping can be
reallocated between group members (
CIRD40705),
- in certain circumstances unpaid tax
arising from a degrouping charge can be recovered from
(principally) some other group members (
CIRD40720),
- expenditure on new assets by other group
members may count for reinvestment relief (
CIRD20400),
- reinvestment relief may also be available
when the reinvestment takes the form of shares in another company
that becomes a group member as a result (
CIRD20420).
