Commentary

D2.307 Group capital gains—Leaving a group

Corporate tax
Corporate tax | Commentary

D2.307 Group capital gains—Leaving a group

Corporate tax | Commentary

D2.307 Group capital gains—Leaving a group

It is often necessary to establish whether a capital gains group remains the same group after there has been a change in its composition, and whether as a consequence a company has left the group.

Specific provisions1 stipulate that a group remains the same group where:

  1.  

    (a)     the same company remains the principal company of the group

  2.  

    (b)     the principal company of a group becomes a member of another group. In this situation, the two groups are regarded as the same group2. This consequence can be continued indefinitely if, say, the new principal company itself

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