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 introduction of changes to the share and security pooling rules in FA 2012, Ch 2, 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 company holding the assets has not actually done anything with them. A number of measures ensure this is so.

First it is made clear that there

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