Medium2 marksMultiple Choice
Corporation tax liabilitiesCorporation TaxGroupsChargeable Gains
This question is part of a case study — click to read the full scenario(Case 21)

Section B - Case 2: Aero-Dynamics Ltd

'Aero-Dynamics Ltd' is a UK resident company manufacturing commercial drones. It owns 100% of 'Hover-Tech Ltd' (UK resident) and 80% of 'Sky-Net Inc' (resident overseas). All companies prepare accounts to 31 March. For the year ended 31 March 2024, Aero-Dynamics Ltd has a trading loss of £400,000. Hover-Tech Ltd has taxable total profits (TTP) of £150,000. Sky-Net Inc has equivalent profits of £200,000.

Which companies form a Group Relief group for trading losses with Aero-Dynamics Ltd?

ACCA · Question 22 · Corporation tax liabilities

Section B - Case 2: Aero-Dynamics Ltd

'Aero-Dynamics Ltd' is a UK resident company manufacturing commercial drones. It owns 100% of 'Hover-Tech Ltd' (UK resident) and 80% of 'Sky-Net Inc' (resident overseas). All companies prepare accounts to 31 March. For the year ended 31 March 2024, Aero-Dynamics Ltd has a trading loss of £400,000. Hover-Tech Ltd has taxable total profits (TTP) of £150,000. Sky-Net Inc has equivalent profits of £200,000.

During the year, Aero-Dynamics Ltd transferred a drone testing facility (a capital asset) to Hover-Tech Ltd. The asset cost £500,000, had a market value of £800,000 at transfer, and a tax written down value of £400,000.

At what value is the transfer deemed to take place for chargeable gains purposes?

Answer options:

A.

£800,000

B.

£400,000

C.

£500,000

D.

£0

How to approach this question

Recognize that the companies form a chargeable gains group. Apply the 'no gain, no loss' rule for intra-group transfers of capital assets.

Full Answer

C.£500,000✓ Correct
Aero-Dynamics Ltd and Hover-Tech Ltd form a chargeable gains group (requires 75% direct/indirect ownership and >50% effective ownership, which is met as it's 100%). Transfers of capital assets within such a group occur on a 'no gain, no loss' basis. This means the deemed transfer proceeds equal the original base cost of £500,000.

Common mistakes

Using market value (£800,000) or confusing capital gains rules with capital allowance rules (TWDV).

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