D6.301 Intra-group reorganisations—scope

Corporate tax
Corporate tax | Commentary

D6.301 Intra-group reorganisations—scope

Corporate tax | Commentary

Division D6.3     Intra-group reorganisations

For updates affecting this Division please see Part D0 Updates

Intra-group reorganisations—overview

D6.301 Intra-group reorganisations—scope

This Division details the tax implications arising from an intra-group transfer/reorganisation of individual chargeable assets or a trade of subsidiary companies.

These transactions are not reorganisations within the strict statutory definition (D6.101–D6.103), but special rules do apply to such transactions to reflect the fact that they take place within a group structure and are a common transaction for companies wishing to restructure their business.

The areas discussed in this division are as follows:


    •     Transfer of capital assets (D6.305–D6.306A)


    •     Transfer of a

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