Taxes Consolidation Act 1997 section 696D

Provisions relating to groups (Chapter 3)

Section 696D allows taxable field expenditure incurred by a company to be treated, by election, as incurred by an associated company within the same group for the purposes of calculating cumulative field expenditure.

• A company that incurs taxable field expenditure may elect to have all or part of that expenditure treated as incurred by a wholly-owned subsidiary, its parent company, or another wholly-owned subsidiary of that parent.
• Where an election is made, the expenditure is deemed to have been incurred by the receiving company at the time it was actually incurred by the electing company.
• The expenditure counts towards the cumulative field expenditure of the receiving company and ceases to count towards that of the electing company.
• The same expenditure cannot be taken into account in determining cumulative field expenditure for more than one taxable field.