Groups of Companies
Group relief, group gains, associated companies, consortia and intra-group transactions.
How to study the ATT Qualification
Use Finance Act 2025 for the 2026 tax papers, complete the three foundational CBEs early, apply professional ethics throughout and concentrate option practice on the one paper you will enter.
Core concepts
Concept 1
Different group definitions apply for loss relief, gains and other corporation-tax purposes.
Exam cue: Draw the ownership structure with percentages and dates.
Concept 2
Group relief reallocates eligible current-period amounts subject to ownership and claim rules.
Exam cue: Apply the group test for the specific relief.
Concept 3
Intra-group asset transfers may be tax neutral initially but create later consequences.
Exam cue: Track claims, surrenders and deferred intra-group gains.
Risk pitfalls and guardrails
Using one group definition for every provision.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Ignoring overlapping accounting periods.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Forgetting degrouping or later disposal consequences.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Memory anchors
Group chart
Record direct, indirect and effective ownership by date.
Purpose test
Choose the statutory group definition for the relief in question.
Group relief
Match eligible surrender and claimant amounts over corresponding periods.
No gain no loss
Qualifying intra-group transfers preserve the gain in the transferee's base cost.
Degrouping
A company leaving the group can crystallise deferred consequences.
Checkpoint rule
Do the check-up only after you can summarize each concept in one sentence and identify one dangerous pitfall from memory.
Knowledge Check (after reading)
Short check-up to confirm understanding of this module.
Check-up Questions
Parent P owns 80% of S's ordinary share capital and has corresponding economic rights. What relationship may exist for group relief?
A loss company joins a group halfway through its accounting period. What limits a group-relief surrender?
Answer all questions to submit.
Next step personalized recommendations
Continue learning
Move forward only after this module is stable.
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