Explanatory Notes

Corporation Tax Act 2009

2009 CHAPTER 4

26 March 2009

Commentary on Sections

Part 8: Intangible fixed assets

Overview

Chapter 9: Application of this Part to groups of companies
Section 777: Relief on realisation and reinvestment: application to group member

2079.This section allows, subject to certain conditions, group members to be treated as the same company for reinvestment relief purposes. It is based on paragraph 56 of Schedule 29 to FA 2002.

2080.Subsection (3)(e) aligns the reference in this section to a “dual resident investing company” with other such references in the source legislation (reproduced in this Part) by introducing a signpost to the provision defining that term.