Commentary

D1.654 Intangible assets—payments between group members for reliefs

Corporate tax
Corporate tax | Commentary

D1.654 Intangible assets—payments between group members for reliefs

Corporate tax | Commentary

D1.654 Intangible assets—payments between group members for reliefs

Where one group member makes a payment to another in respect of group rollover relief (see D1.647) or the reallocation of a degrouping charge (see D1.652), the payment is ignored for corporation tax purposes up to specified limits1.

A payment for group rollover relief is one made in connection with a rollover relief claim allowing a gain on realisation made by one company to be reinvested in expenditure by another, or the provisions allowing the acquisition of a group company to be treated as the acquisition of the underlying intangible assets (see D1.647)2.

The

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