Commentary

D2.316 Group capital gains—Transfer within group to venture capital trust

Corporate tax
Corporate tax | Commentary

D2.316 Group capital gains—Transfer within group to venture capital trust

Corporate tax | Commentary

D2.316 Group capital gains—Transfer within group to venture capital trust

A transfer of an asset to a group company which is a venture capital trust at the time of transfer cannot be a no gain/no loss transfer1 as a venture capital trust is exempt from tax on chargeable gains2.

Where an asset is transferred to a group company (as a no gain/no loss transfer)3 and the transferee subsequently becomes a venture capital 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 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