IFM02290 - Authorised investment funds (AIFs): taxation of funds: groups and group relief claims
Regulation 94 of SI 2006/964
An authorised investment fund (AIF) cannot be a member of a group for corporation tax purposes and cannot claim or surrender group relief.
Capital Gains or losses
An AIF is not within the charge to corporation tax on chargeable gains (CG) and it is not possible for an AIF to be the principal company or to be a member of a CG group.