Commentary

D2.314 Group capital gains—Intra-group transfers: Exclusions

Corporate tax
Corporate tax | Commentary

D2.314 Group capital gains—Intra-group transfers: Exclusions

Corporate tax | Commentary

D2.314 Group capital gains—Intra-group transfers: Exclusions

The no gain/no loss treatment for intra-group transfers described at D2.310–D2.313 does not apply to the following disposals1:

  1.  

    (a)     a disposal of a debt due from the transferee company effected by satisfying it (or part of it)2

  2.  

    (b)     a disposal of redeemable shares in a company on the occasion of their redemption3

Example 1

  1.  

    Q Ltd owned the whole of the ordinary share capital of R Ltd and 1,000 £1 redeemable preference shares in R Ltd which cost £950; the redeemable shares were redeemed at par. Q Ltd will realise a chargeable gain of £50. (The no gain/no loss provisions do not apply to this

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