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Hi there can anyone help?
I’m struggling to understand why 2 groups of companies controlled by the sme person aren’t able to benefit from rollover relief between then 2 seperate groups?
This also casts doubt on my understanding of gains groups and group relief groups!!
Can anyone explain (in primary school language!)
Thank you
Because in theory one person could go around and open up lots of companies own all of them 100% and take advantage of each company having it’s own seperate tax rate bands etc.
Therefore companies are deemed to be under common control, are restricted on acitivities that may give rise to tax advantages such as AIA i believe is only allowed once per company.
imagine if an individual went around opening up loads of companies and splitting up his trade from his man companies.
He could have as many AIA as he liked. He would only pay lower rate corporation tax as every time profits came near 300k he would open another company.
To stop this companies under common control are restricted
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