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For guidance on expenses incurred by grouped or associated trading companies to which Case I rules apply, see BIM42140.

CTA09/S54 has no direct relevance to management expenses under CTA09/S1219 but a holding company has no special position in relation to Section 1219 because it happens to be part of a group. It is a member of a group because of the degree of its investments in other companies and the other companies remain separate legal entities. »Ê¹ÚÌåÓýapp allowable expenses under Section 1219 must still be the expenses of managing the holding company's investments, and not the businesses or trades of the subsidiary companies.

You may have a case of a holding company where there is some intermingling of the management of the business of the holding company and the businesses of the subsidiary companies. In such a case, in practice, you need not disallow expenses:

• if the expenses would have been allowable for UK tax purposes if incurred by the subsidiary,

and

• if the holding company arranges to charge out future expenses to the subsidiary.