{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-1004",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-1004.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/1004",
  "kind": "section",
  "number": "1004",
  "heading": "Groups, consortiums and commercial associations of companies",
  "text": "(1) This section applies for the purposes of this Part.\n(2) Two companies are members of the same group if one is a 51% subsidiary of the other or both are 51% subsidiaries of a third company.\n(3) “Group transfer” means a transfer of a business, or a part of a business, from one company that is a member of a group to another company that is, or two or more companies that are, members of the group.\n(4) A company is a parent company of another company if that other company is its 51% subsidiary.\n(5) A company (“the consortium company”) is owned by a consortium if—\n(a) five or fewer companies (“the shareholding companies”) between them beneficially own at least 75% of the consortium company's ordinary share capital, and\n(b) each of the shareholding companies beneficially owns at least 10% of that capital.\n(6) Each shareholding company is a member of the consortium.\n(7) For the purposes of subsection (5) the shareholdings of members of a group of companies are to be treated as held by a single company.\n(8) And, in such a case, a member of the group of companies is a member of the consortium if the member beneficially owns some of the consortium company's ordinary share capital.\n(9) “Commercial association of companies” means a company together with such of its associated companies (as defined in section 449 of CTA 2010) as carry on businesses that are of such a nature that the businesses of the company and the associated companies, taken together, may be reasonably considered to make up a single composite undertaking.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in s. 1004(9) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 665 (with Sch. 2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/4/section/1004",
    "retrieved_at": "2026-10-29T09:11:19.560467+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}