Answer to Example 5 An election may be made, the matching election, to deem any part of a gain or loss made by one
gains group member to have been made by any other gains group member. This will allow gains and
losses to be set o
ff
within the group rather than carrying forward an unused capital loss in one group
company while being taxed on a gain in another group company.
Initially therefore it would appear that electing to either deem the loss made by Large Ltd to have
been made by Smaller Ltd, or deeming £35,000 of Smaller Ltd’s gain to have been made by Large
Ltd would have the same e
ff
ect of matching the gains with the losses and either approach may be
proposed, but there is a further issue to be identified that will suggest that it would be preferable to
transfer at least £50,000 of the gain from Smaller Ltd to Large Ltd.
Both companies are currently large companies, which notwithstanding their size in the previous
accounting period (AP) will mean that they will both be required to make quarterly instalment
payments in relation to the next AP if they are both estimating large profits for that period.. This will
result in an adverse cash flow position for both group companies. They are large companies as their
profits are above the profits threshold of £750,000 (£1.5M divided between two 51% related group
companies).
It would be beneficial therefore to transfer at least £50,000 of the gain from Smaller Ltd to Large Ltd
which will bring Smaller Ltd’s profits down from £800,000 to £750,000 and will therefore remove the
requirement for Smaller Ltd to make quarterly instalment payments for the next AP. This result would
not be achieved if the loss was transferred to Smaller Ltd as this would still leave Smaller Ltd with
profits in excess of £750,000.
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