½Û×ÓÊÓƵ

Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.6 Intangible fixed assets /Corporate intangible regime—groups / D1.650 Intangible assets—exemptions from the degrouping charge
Commentary

D1.650 Intangible assets—exemptions from the degrouping charge


Corporate tax

There are exemptions from the degrouping charge, which are broadly the same as those in the capital gains grouping rules (see D2.331) and are as follows1:

  1. Ìý

    •ÌýÌýÌýÌý a relevant share disposal

  2. Ìý

    •ÌýÌýÌýÌý associated companies leaving group at the same time

  3. Ìý

    •ÌýÌýÌýÌý principal company becoming member of another group

  4. Ìý

    •ÌýÌýÌýÌý demerger provisions apply

  5. Ìý

    •ÌýÌýÌýÌý merger carried out for genuine commercial reasons

  6. Ìý

    •ÌýÌýÌýÌý group member ceasing to exist

  7. Ìý

    •ÌýÌýÌýÌý prior to IP completion day2, the formation of a Societas Europaea by merger

  8. Ìý

    •ÌýÌýÌýÌý transfer of a UK business to another company

These are detailed further below.

Degrouping exemption—relevant share disposal

Where a company ceases to be a member of a group on or after 7 November 2018, a degrouping charge will not arise where the company leaves the group as a result of a share disposal by another company where that share disposal qualifies for the substantial shareholding exemption (SSE) under TCGA 1992, Sch

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
TAKE A FREE TRIAL TAKE A FREE TRIAL

Web page updated on 17 Mar 2025 14:38