Commentary

C2.1135 NRCGT groups

Capital gains tax
Capital gains tax | Commentary

C2.1135 NRCGT groups

Capital gains tax | Commentary

C2.1135 NRCGT groups

The rules in C2.1130–C2.1138 apply to disposals made prior to 6 April 2019. For disposals made on or after 6 April 2019, see C2.1139–C2.1173. Transitional rules apply to unused losses existing at 6 April 2019 that have accrued on disposals made prior to that date. See C2.1142 for further details.

An election can be made by a group of companies1 (the NRCGT group2) to pool NRCGT gains and losses. All members of the group which are qualifying members must make the election. The 'qualifying members' are all the members of the group which meet the qualifying conditions on the date the election specifies it is to have effect. The 'qualifying conditions' are that the company is a non-resident and closely-held company (see C2.1131) which is not carrying on life assurance business (see D7.411) and does not hold any chargeable residential assets but which does hold an asset the disposal of which would be a disposal of a UK residential property interest (see

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