AIA (change of ownership)

AIA (change of ownership)

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Hi

Group X have an accounting period for the 12m to Dec 15. It is owned by A until June 15 and then by B thereafter. It is my understanding that AIA available to Group X depends on who controls the group at the end of the chargeable period, i.e. at 31 December 2015. As this is B, Group X only needs to worry about the AIA already claimed by B and not A. 

If we assume B owns no other business, then Group X is allowed a full £500k AIA, even if A's business have claimed some AIA (let's assume £100k).

If this is correct, then I would've thought there would be some anti-avoidance to stop companies playing about with their year ends to maximise their AIA claims. In the example above, if Group X had changed it's year end to 31 May 2015, and then back to 31 December 2015, the total AIA available to it for those 12 months would be £400k (as it would've had to factor in the £100k already claimed by A in it's first chargeable accounting period).

Admittedly in this example, the group would be losing out on AIA by changing it's year end, but if it had been the otherway around, the group could've manipulated it's AIA upwards.

Am I missing something?

Cheers

 

 

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