Commentary

D2.318 Group capital gains—Transfers to a group company resident in an EEA state

Corporate tax
Corporate tax | Commentary

D2.318 Group capital gains—Transfers to a group company resident in an EEA state

Corporate tax | Commentary

D2.318 Group capital gains—Transfers to a group company resident in an EEA state

For accounting periods ending on or after 10 October 2018 where a company transfers an asset to a group company that is resident in an EEA state (other than the UK) that is not within the charge to corporation tax, it is possible for the payment of the corporation tax payable as a result of the transfer to be deferred.

In order for such deferral to be available the transfer must be a transfer to which TCGA 1992, s 171 would have applied had the transferee been UK resident at the time of the transfer1.

Where this relieving provision

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