Commentary

D2.330 Group capital gains—Degrouping charge

Corporate tax
Corporate tax | Commentary

D2.330 Group capital gains—Degrouping charge

Corporate tax | Commentary

D2.330 Group capital gains—Degrouping charge

A degrouping charge is triggered when a company leaves a group holding an asset (that is within the scope of UK tax on capital gains) which it acquired within the previous six years by way of an intra-group transfer made at a time when both companies concerned were members of the same group1.

This charge is calculated by deeming the company to have disposed of and reacquired the asset at its market value at the time of the original intra-group transfer2. The rules described at D2.325–D2.329 (computation, indexation etc) apply equally when calculating the degrouping gain

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