Commentary

D2.301 Overview of group capital gains

Corporate tax
Corporate tax | Commentary

D2.301 Overview of group capital gains

Corporate tax | Commentary

Division D2.3     Group capital gains

For updates affecting this Division please see Part D0 Updates

Group capital gains—overview

D2.301 Overview of group capital gains

Special capital gains provisions apply in relation to groups of companies. Essentially these provisions mean that:

  1.  

    (a)     transfers of assets between group members must be treated as taking place on a no gain/no loss basis. (The intention of these provisions is to treat all companies in a group as a single entity so that effectively the mere transfer of an asset within the group is disregarded for capital gains purposes)1

  2.  

    (b)     group companies can elect for a

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