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As outlined in C3.301 rollover relief is available where the whole or part of the proceeds of the disposal of a qualifying asset used for the purposes of a trade are matched with the acquisition of a qualifying replacement other asset to be used for the trade. In the case of a group of companies the basic provisions of rollover relief are modified¹ so that it is possible to roll over a chargeable gain on the disposal of a business asset by one trading member of the group against the acquisition of a replacement business asset by another trading member². This is achieved by treating all the trades carried on by members of a group as one trade. In applying this rule:

1. Ìý

   •ÌýÌýÌýÌý non-trading group companies are treated as trading companies if they acquire or dispose of assets used only for the purposes of any of the trading activities of the group, and

2. Ìý

   •ÌýÌýÌýÌý there is no requirement for both companies to be UK resident. All that is required