Digital Tax Service · Guidance

Holding companies and group structures

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Holding company and group structure, in navy and gold

What a group looks like

At the top sits the holding company (“holdco”), which owns the shares in one or more trading subsidiaries. The holdco usually doesn’t trade; it holds shares and often valuable assets. It’s an ordinary limited company — “holding company” describes its role, not a special legal form.

Why owners use a holding company

  • Protect assets — keep property, cash or IP in the holdco, away from the risk of the trading company
  • Easier sale — sell one trading subsidiary without disturbing the rest of the group
  • Move profits up tax-free — subsidiary dividends to the parent are generally exempt, ready to reinvest or hold
  • Bring in investors or separate distinct business lines cleanly

The tax features

  • Tax-free inter-company dividends — profits flow up to the holdco without a further Corporation Tax charge
  • Group relief — one company’s losses can shelter another’s profits
  • Substantial Shareholding Exemption — a gain on selling a qualifying trading subsidiary can be exempt from Corporation Tax
  • VAT groups — group companies can register for VAT together in some cases

The associated-company trap

The flip side: the £50,000 and £250,000 Corporation Tax thresholds are divided between associated companies. A holdco plus two trading subsidiaries means each company’s small-profits band is a third of the size — pushing profits into the 26.5% marginal band, or the 25% rate, sooner. A group also means more accounts and returns.

How associated companies affect the CT bands

Restructure carefully

A group can be very effective — but moving shares or trades into a new structure has Stamp Duty, Capital Gains and other consequences, and isn’t worth doing without a clear reason. We’ll tell you whether a holding company genuinely helps you and handle the group accounts if you have one. Call 0114 327 1480.

Company formation & structure

Frequently asked questions

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