Commentary

D2.315 Group capital gains—Transfer within group to investment trust

Corporate tax
Corporate tax | Commentary

D2.315 Group capital gains—Transfer within group to investment trust

Corporate tax | Commentary

D2.315 Group capital gains—Transfer within group to investment trust

A transfer of an asset to a group company which is an investment trust at the time of transfer cannot be a no gain/no loss transfer1, as an investment trust is exempt from tax on chargeable gains2. See D7.332 for the definition of an investment trust.

Where an asset is transferred to a group company (as a no gain/no loss transfer3) and the transferee subsequently becomes an investment trust, the transferee company is deemed to have sold and reacquired the asset at market value immediately after the initial transfer (although the gain or loss is not deemed to arise until the end of the accounting period before

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial