| Commentary

253.1 Capital gains

| Commentary

C: SALE BETWEEN TWO COMPANIES IN THE SAME GROUP

253 Tax and stamp duty land tax advantages

There are significant tax and stamp duty land tax advantages when a business is transferred by one company in a group to another member of the same group.

253.1 Capital gains

Where a member of a group of companies disposes of an asset to another member of that group, there is in effect a deferral of any corporation tax because both members are treated as if the asset was acquired for such consideration as would secure neither a gain nor a loss on the disposal1. Effectively,

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