The group contribution rules in Chapter 35 of the Income Tax Act (IL) enable groups to equalize the results of different group companies by offsetting tax surpluses arising in some group companies against deficits arising in others. Offsetting takes place by companies with surpluses (donor companies) receiving deductions for group contributions made, which are instead taxed by companies with deficits (recipient companies). In order for there to be group contribution rights between the companies, there are several requirements, one of which is that there is a transfer of value from the donor to the recipient corresponding to the amount of the group contribution. From a purely tax law point of view, the value transfer requirement may seem relatively unproblematic. However, in combination with company law and accounting rules, it often proves to be more difficult than it might first appear to achieve the desired equalization of results. In short, the proposed study aims to make proposals for simplification, in one or more of the areas mentioned, so that the equalization of profits can be achieved more easily and in more cases than today.