Corporation Tax Act 2009 section 1140A

Groups

Section 1140A defines when two companies are considered to be in the same group for the purposes of the intangible fixed assets rules in Part 8 of the Corporation Tax Act 2009.

• This section provides a single, consistent definition of "group" for the intangible fixed assets regime.
• Two companies are in the same group if they meet the group definition used in Part 5 of the Corporation Tax Act 2010 (the group relief rules).
• In broad terms, this means a parent company and its 75% subsidiaries form a group, as do any two companies that are both 75% subsidiaries of the same parent.
• This provision was introduced by Finance Act 2024 and ensures that the group concept applied to intangible assets aligns with the well-established group relief framework.