There is no provision for a degrouping charge to be dealt with other than in the transferee company which is leaving the group. This can prevent the charge being sheltered by any reliefs available in the main group. In order to allow relief in this respect, the company leaving the group ('X') can elect jointly with another company remaining in the group ('B') that all or part of a degrouping gain on an intangible fixed asset should be treated as if it accrued to B1.
To be eligible to make the election, B must have been a member of the same group as X immediately before X left the group2. Where the degrouping charge has arisen as a result of the principal company in the original group becoming a member of a second group and then X leaving
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
Web page updated on 17 Mar 2025 16:06