Commentary

D2.334 Group capital gains—Degrouping charge: Parent company leaving a group

Corporate tax
Corporate tax | Commentary

D2.334 Group capital gains—Degrouping charge: Parent company leaving a group

Corporate tax | Commentary

D2.334 Group capital gains—Degrouping charge: Parent company leaving a group

A degrouping charge can arise in a similar way to the normal degrouping charge described in D2.330 where the parent company joins another group.

As for the normal degrouping charge the charge can be dealt with in a company other than the departing company (see D2.329) and there is an alternative mechanism for applying the charge (D2.333).

Company takeover

The general rule is that if the parent company of a group becomes a member of another group, the two groups are treated as the same1. But it does not follow that all the subsidiaries of the original parent company become members of the reconstituted group, as they may not be effective 51%

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