Taxes Consolidation Act 1997 section 696J

Provisions relating to groups

Section 696J allows a company that incurs eligible expenditure on a taxable field to elect that some or all of that expenditure be treated as incurred by an associated group company for the purposes of calculating cumulative field costs.

• A company that incurs eligible expenditure may elect to transfer it to a wholly-owned subsidiary, its parent company, or another wholly-owned subsidiary of the parent.
• Transferred expenditure is treated as incurred by the receiving company at the time it was actually incurred by the transferring company, and is included in the receiving company's cumulative field costs while being excluded from the transferring company's.
• The same expenditure cannot be counted towards the cumulative expenditure of more than one taxable field.
• The definition of wholly-owned subsidiary in section 694(5) applies for the purposes of this section.