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    PracticeACCAACCA TX — Taxation Practice Exam 2Question 14
    Hard2 marksMultiple Choice
    Corporation tax liabilitiesSection ACorporation TaxGroupsCapital Gains

    ACCA · Question 14 · Corporation tax liabilities

    Section A

    Alpha Ltd owns 80% of Beta Ltd. Beta Ltd owns 80% of Gamma Ltd. All companies are UK resident.

    Do Alpha Ltd and Gamma Ltd form a Capital Gains Group?

    Answer options:

    A.

    Yes, because there is a direct 80% holding at each level.

    B.

    Yes, because Beta Ltd is a 75% subsidiary of Alpha Ltd, Gamma Ltd is a 75% subsidiary of Beta Ltd, and Alpha Ltd has an effective interest of more than 50% in Gamma Ltd.

    C.

    No, because Alpha Ltd's effective interest in Gamma Ltd is less than 75%.

    D.

    No, because capital gains groups only apply to 100% subsidiaries.

    How to approach this question

    Apply the two tests for a capital gains group: 1) Is there a 75% direct holding at each level? (Yes, 80% > 75%). 2) Is the principal company's effective interest > 50%? (80% x 80% = 64% > 50%).

    Full Answer

    B.Yes, because Beta Ltd is a 75% subsidiary of Alpha Ltd, Gamma Ltd is a 75% subsidiary of Beta Ltd, and Alpha Ltd has an effective interest of more than 50% in Gamma Ltd.✓ Correct
    To form a Capital Gains Group, two conditions must be met: 1) Each subsidiary must be a 75% direct subsidiary of another company in the group. (Beta is 80% of Alpha; Gamma is 80% of Beta. Both meet the 75% test). 2) The principal company (Alpha) must have an effective interest of more than 50% in the subsidiary. Alpha's effective interest in Gamma is 80% x 80% = 64%. Since 64% is greater than 50%, Gamma is in the capital gains group.

    Common mistakes

    Assuming the effective interest must also be 75%.
    Question 13All questionsQuestion 15

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