Commentary

D2.352 Group capital gains—Dividend stripping

Corporate tax
Corporate tax | Commentary

D2.352 Group capital gains—Dividend stripping

Corporate tax | Commentary

D2.352 Group capital gains—Dividend stripping

The depreciatory transactions provisions discussed in D2.350 are extended1 to counter the creation of certain capital losses by dividend stripping in a 'non-group' situation. Essentially where these rules apply, the depreciatory transaction provisions2 have effect such that on any disposal of some or all of the shares or securities comprised in the holding the distribution is treated as if it were a depreciatory transaction and the companies concerned were all members of a group whether or not this is the case3. This applies regardless of whether the disposal is by the first company or any

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