Commentary

D2.310 Group capital gains—Overview of intra-group transfers

Corporate tax
Corporate tax | Commentary

D2.310 Group capital gains—Overview of intra-group transfers

Corporate tax | Commentary

Group capital gains—Intra-group transfers

D2.310 Group capital gains—Overview of intra-group transfers

Transfers of capital assets between group companies are deemed to take place for a consideration that will give rise to neither a gain nor a loss. If the qualifying conditions are met (see D2.311), this treatment is mandatory and no election is necessary1. For exclusions from no gain/no loss treatment see D2.314.

Example

A Ltd owns 100% of B Ltd. In September, Year 1, A Ltd purchased a property at a cost of £500,000. In January, Year 6, A Ltd decided to transfer this property to B Ltd. The transfer

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