A company and its 75% owned UK subsidiaries (as measured by ordinary share capital). Ownership can be traced through non-resident companies (which are not group members themselves). Anti-avoidance provisions exist to deny membership to subsidiaries that do not provide ownership benefits to a parent company in excess of 50% of profits available for distribution or 50% of assets on a winding up. One company in a capital gains group can transfer capital assets to another company in the group without giving rise to a chargeable gain or an allowable loss (section 171, Taxation of Chargeable Gains Act 1992).