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Group Relief and Foreign Subsidiaries

Group Relief and Foreign Subsidiaries

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This might be a specialist area of expertise, but I will give it a try.

Company A is a UK company which holds 100% shares in Company B which is a US Limited Liability Company. Company A is itself a 100% subsidiary of Company C, a French limited company. Company B has made losses historically and as of today has accumulated losses of approximately £1m. Company B owes around £1m to Company A in loans. It is now proposed that Company A sells the subsidiary Company B for a nominal amount to Company C (the ultimate holding company).

What is the most tax efficent way relieving accumulated trading losses in the foreign subsidiary, and how can the loss on loan be best relieved?

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By paul.benny
23rd Oct 2020 14:06

This question is best asked of your group's advisers who will be in possession of more of the facts than proffered here.

Not only that, this is complex international tax planning. You shouldn't expect to get that kind of specialist advice for free.

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Replying to paul.benny:
By Wilson Philips
23rd Oct 2020 14:17


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