Commentary

D1.8102 Degrouping charge

Corporate tax
Corporate tax | Commentary

D1.8102 Degrouping charge

Corporate tax | Commentary

D1.8102 Degrouping charge

Where a derivative contract has been transferred intra group under CTA 2009, s 625 and the transferee company ceases to be a member of the relevant CGT group within six years of the date of the original transfer and after 31 March 2014 the transferee is deemed to dispose of the derivative contract at its fair value at the date that the transferee ceases to be a member of the group1.

Where a transferee ceased to be a member of the group within six years of the transfer and before 1 April 2014, it was deemed to have disposed of and reacquired the contract at its market value immediately before it ceased to be a member of the group where the deemed disposal of acquisition gave rise to a credit.

Where a loss would have arisen arise as a result of the deemed disposal and reacquisition, a disposal was only deemed to take place where there was a hedging relationship (see below) between the derivative contract and a creditor loan relationship which had been transferred to the company under the equivalent group transfer provisions of

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