Commentary

D1.652 Intangible assets—reallocation of degrouping charge within group

Corporate tax
Corporate tax | Commentary

D1.652 Intangible assets—reallocation of degrouping charge within group

Corporate tax | Commentary

D1.652 Intangible assets—reallocation of degrouping charge within group

There is no provision for a degrouping charge to be dealt with other than in the transferee company which is leaving the group. This can prevent the charge being sheltered by any reliefs available in the main group. In order to allow relief in this respect, the company leaving the group ('X') can elect jointly with another company remaining in the group ('B') that all or part of a degrouping gain on an intangible fixed asset should be treated as if it accrued to B1.

To be eligible to make the election, B must have been a member of the same group as X immediately before X left the

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