Commentary

C3.302B Entitlement to rollover relief—groups of companies

Capital gains tax
Capital gains tax | Commentary

C3.302B Entitlement to rollover relief—groups of companies

Capital gains tax | Commentary

C3.302B Entitlement to rollover relief—groups of companies

In the case of a group of companies the basic provisions of rollover relief are modified, as follows1:

  1.  

    •     all the trades carried on by members of a group of companies are treated as one trade. This means that it is possible to roll over a chargeable gain on the disposal of a business asset by one trading member of a group against the acquisition of a replacement business asset by another trading member of the group2

  2.  

    •     non-trading group companies are treated as trading companies if they acquire or dispose of assets used only for the purposes of any of the trading activities of the group, and

  3.  

    •     there is no requirement for both companies to be UK resident. All that is required is that the asset concerned is within the scope of the UK taxation. This therefore means that the reliefs are available for non-UK companies trading in the UK through a

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