Commentary

D2.345 Group capital gains—Recovery of tax from other group members

Corporate tax
Corporate tax | Commentary

D2.345 Group capital gains—Recovery of tax from other group members

Corporate tax | Commentary

Group capital gains—Administration

D2.345 Group capital gains—Recovery of tax from other group members

HMRC can recover unpaid corporation tax on chargeable gains from other group members or, in certain cases, a controlling director, where1:

  1.  

    (a)     the gain accrues either to a company that is UK resident or (to a non-UK resident company) on an asset that is within the charge to UK corporation tax at the time of accrual2; and

  2.  

    (b)     all or part of the corporation tax assessed on the taxpayer company for the accounting period in which the gain accrues remains unpaid six months after it became

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