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Mat Ltd has the following holdings in its subsidiaries:
60% of Neath Ltd
80% of Overseas Inc
90% of Powys Ltd
Overseas Inc is a company resident in Canada and does not have a UK trading branch.
Powys Ltd has a subsidiary, Quorn Ltd, of which it owns 80% of the issued share capital.
Between which companies is group relief for losses available?
A. Mat Ltd and Overseas Inc.
B. Mat Ltd and Neath Ltd.
C. Mat Ltd and Powys Ltd.
D. Powys Ltd and Quorn Ltd.
E. Mat Ltd, Neath Ltd and Overseas Inc.
正确答案:C,D
答案解析:
The correct answers are: Mat Ltd and Powys Ltd; Powys Ltd and Quorn Ltd.
Losses can only be surrendered between Mat Ltd and Powys Ltd.
Overseas companies not based in the EEA are excluded for group relief purposes except to the extent that they generate profits in a UK branch.
Mat Ltd's interest in Quorn Ltd is 90% × 80% = 72%. Thus Quorn Ltd is excluded from the group (for group relief only).
Powys Ltd and Quorn Ltd form a separate group.
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