Medium2 marksMultiple Choice
Corporation tax liabilitiesCorporation TaxGroupsGroup Relief

ACCA · Question 21 · Corporation tax liabilities

Section B - Case 2: Aero-Dynamics Ltd

'Aero-Dynamics Ltd' is a UK resident company manufacturing commercial drones. It owns 100% of 'Hover-Tech Ltd' (UK resident) and 80% of 'Sky-Net Inc' (resident overseas). All companies prepare accounts to 31 March. For the year ended 31 March 2024, Aero-Dynamics Ltd has a trading loss of £400,000. Hover-Tech Ltd has taxable total profits (TTP) of £150,000. Sky-Net Inc has equivalent profits of £200,000.

Which companies form a Group Relief group for trading losses with Aero-Dynamics Ltd?

Answer options:

A.

Aero-Dynamics Ltd and Hover-Tech Ltd only.

B.

Aero-Dynamics Ltd, Hover-Tech Ltd, and Sky-Net Inc.

C.

Hover-Tech Ltd and Sky-Net Inc only.

D.

None of the companies.

How to approach this question

Identify the ownership percentages (must be >= 75%) and the residency status of the companies. Group relief is generally restricted to UK resident companies.

Full Answer

A.Aero-Dynamics Ltd and Hover-Tech Ltd only.✓ Correct
A Group Relief group requires a 75% direct or indirect ownership structure. Aero-Dynamics Ltd owns 100% of Hover-Tech Ltd and 80% of Sky-Net Inc, so the 75% test is met for both. However, group relief is generally only available between UK resident companies. Therefore, only Aero-Dynamics Ltd and Hover-Tech Ltd can surrender/claim losses between each other.

Common mistakes

Including the overseas subsidiary in the UK group relief group.

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