Commentary

D7.4108 Transition to the new pooling rules

Corporate tax
Corporate tax | Commentary

D7.4108 Transition to the new pooling rules

Corporate tax | Commentary

D7.4108 Transition to the new pooling rules

The rules in this division apply for accounting periods beginning on or after 1 January 2013. For accounting periods beginning before 1 January 2013 see Division D7.5.

The introduction of changes to the share and security pooling rules in FA 2012 Ch2 Pt 8 (see D7.445) means that the transition to the new regime offers the theoretical possibility of a change of tax category and hence a disposal for capital gains tax purposes on transition.

Clearly the new regime ought not to trigger a capital gains charge simply by virtue of its introduction since the

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