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Corporation Tax Part 2 - Large Companies and Groups

Part 2 is a standalone course which covers large UK companies and groups and more detailed corporation tax rules than is covered on the Part 1 course. Attendance on Part 1  is not essential as the course includes refresher points on these aspects of Corporation Tax but a basic understanding of the essential principles and computational aspects of corporation tax in the UK is assumed. Any recent developments in UK group taxation law and practice will also be covered together with any recent case law decisions which are likely to be of day to day relevance to the busy group tax manager or adviser. At the end of the course delegates will benefit from an understanding of the taxation consequences of creating a group having worked through a variety of computations on group taxation, group relief, group capital gains.  They will also gain an appreciation of problem areas in group taxation and planning.

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Learning Objectives


Aimed at newcomers to corporation tax in larger companies and groups, as well as those requiring a refresher, it covers the main issues affecting larger UK corporates. At the end of the course delegates should be able to successfully identify and deal with the chief computational and compliance aspects of their company and group tax reporting obligations. The course is intended for those who need a practical introduction to the different areas of group corporation tax particularly computations, group relief, and group tax responsibilities. The aim is to equip delegates with a good knowledge of the UK’s current group taxation regime and the various features of it which can be of relevance to business tax and compliance and planning the tax affairs of a small, medium or large group on a day to day basis.

Course Content

Introduction to group taxation

  • Loss relief
  • Recent changes to loss relief rules and procedures
  • Group relief rules and claims procedures
  • Expenses reliefs
  • Management expenses
  • Rental income losses
  • Practical introduction to group classifications for taxation
  • What is and is not a group
  • Brief introduction to consortium reliefs
  • Group tax computations, group relief for losses, consortia relief for losses
  • Claims procedures and rules
  • Group payment arrangement for corporation tax, group taxation administration
  • Companies joining and leaving a group, group transfers of trade
  • Group capital gains and how to mitigate them, and planning
  • Inter-group transactions and the tax consequences
  • Group capital gains rules and losses rules
  • Group gains and losses elections

Financial income aspects

  • Loan relationships
  • Charges on income
  • The foreign profits exemption
  • The Worldwide debt cap – brief introduction
  • Double taxation relief
  • Foreign exchange transactions

Specific reliefs and avoidance provisions

  • Transfers of trade and loss relief rules
  • Major changes in trade rules
  • Capital gains and losses – rules and planning?
  • Inter-group rules and procedures
  • The substantial shareholdings exemption

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