Medium2 marksMultiple Choice
Corporation tax liabilitiesCorporation TaxGroupsRollover Relief
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 25 · 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.

Hover-Tech Ltd sold a freehold factory on 1 May 2023, realizing a chargeable gain of £120,000. Aero-Dynamics Ltd purchased a new freehold factory on 1 August 2023.

Can the gain made by Hover-Tech Ltd be rolled over against the acquisition made by Aero-Dynamics Ltd?

Answer options:

A.

No, rollover relief can only be claimed if the same company buys and sells the assets.

B.

Yes, because they are members of the same chargeable gains group.

C.

No, because the new asset was purchased after the old asset was sold.

D.

Yes, but only 50% of the gain can be rolled over.

How to approach this question

Recall the group rules for rollover relief. Members of a 75% chargeable gains group are treated as a single entity for rollover relief purposes.

Full Answer

B.Yes, because they are members of the same chargeable gains group.✓ Correct
Aero-Dynamics Ltd and Hover-Tech Ltd form a chargeable gains group. For the purposes of rollover relief, all trades carried on by members of a chargeable gains group are treated as a single trade. Therefore, a gain made by one group member (Hover-Tech) can be rolled over against the cost of a qualifying replacement asset purchased by another group member (Aero-Dynamics).

Common mistakes

Assuming rollover relief is strictly on a company-by-company basis.

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