| Commentary

282 In general

| Commentary

5: ISSUES ARISING FOR TRANSFERRED COMPANIES

282 In general

Where shares in a subsidiary company change hands as a result of a company reorganisation, the change in ownership should not generally affect the tax affairs of the company itself1. However, there are two issues which should be borne in mind:

  1. 282.1

        where there have been transfers of chargeable assets to the subsidiary from other members of its group during the previous six years, there may be a degrouping charge under the provisions of Section 179 of the Taxation of Chargeable Gains Act 1992;

  2. 282.2

        where there is

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