Comparative Guides

Welcome to Mondaq Comparative Guides - your comparative global Q&A guide.

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4. Results: Answers
Corporate Tax
Is tax consolidation permitted, on either a tax liability or payment basis, or both?

Answer ... Outside of value added tax, the United Kingdom does not permit tax consolidation on a liability basis. However, it allows companies within a group to surrender losses to each other through its group relief regime (see question 1.6).

With regard to consolidation on a payment basis, companies within a group can enter into a group payment arrangement with Her Majesty’s Revenue and Customs (HMRC) (respectively, a ‘payment group’ and a ‘group payment arrangement’) in respect of the payment of corporation tax by the payment group. While a payment group nominates one company to make payments to HMRC, each payment group company remains individually liable for the timely payment of the amount of tax it owes.

For more information about this answer please contact: James Anderson from Skadden, Arps, Slate, Meagher & Flom (UK) LLP