Commentary

D2.335 Group capital gains—Claim for reduction of degrouping charge

Corporate tax
Corporate tax | Commentary

D2.335 Group capital gains—Claim for reduction of degrouping charge

Corporate tax | Commentary

D2.335 Group capital gains—Claim for reduction of degrouping charge

A claim can be made for the adjustment of a degrouping charge in cases where it would be unreasonable for such a charge to apply1. These provisions apply where there is a gain that accrues either to the target company or to one or more vendor companies (ie where the alternative mechanism applies, see D2.333). The company to which the gain would accrue (either the vendor company or the target company) may make a clam for the gain to be reduced for all purposes by an amount that must be specified

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