Revenue Note for Guidance
This section contains certain provisions in relation to groups. This section provides that capital expenditure incurred by a company may, in certain circumstances, be deemed to have been incurred by an associated company for the purposes of calculating the cumulative expenditure figure, where one company is a subsidiary of the other or both are subsidiaries of a third company.
(1) Where taxable field expenditure on a taxable field is incurred by one company (the first company) and the first company either —
then the first company can elect that the expenditure is deemed to have been incurred —
(2) Where expenditure is deemed to have been incurred by a company (the other company) following an election under subsection (1), then —
(3) Provision is made to ensure that the same expenditure is not double counted for the purposes of determining the cumulative figures.
(4) The definitions of subsidiary, etc. in section 694 are applied for the purposes of this section.
Relevant Date: Finance Act 2021