Commentary

D6.305 Transfers of capital assets within a capital gains group—General rule

Corporate tax
Corporate tax | Commentary

D6.305 Transfers of capital assets within a capital gains group—General rule

Corporate tax | Commentary

Intra-group transfers of capital assets

D6.305 Transfers of capital assets within a capital gains group—General rule

Usually, the transfer of any chargeable assets between members of a chargeable gains group is made on a no gain/no loss basis for capital gains purposes1.

However, this rule is disapplied for a share exchange that is treated as a reorganisation of share capital 2, see D6.306 for further details.

The no gain/ no loss position for capital assets is similar as regards the transfer of goodwill, intellectual property and other intangibles under the tax regime for such assets introduced with effect from 1

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