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Commentary

D2.314 Group capital gains—intra-group transfers—exclusions


Corporate tax

The no gain/no loss treatment for intra-group transfers described at D2.310–D2.313 does not apply to the following disposals1:

  1. Ìý

    (a)ÌýÌýÌýÌý a disposal of a debt due from the transferee company effected by satisfying it (or part of it)2

  2. Ìý

    (b)ÌýÌýÌýÌý a disposal of redeemable shares in a company on the occasion of their redemption3

Example 1

  1. Ìý

    Q Ltd owned the whole of the ordinary share capital of R Ltd and 1,000 £1 redeemable preference shares in R Ltd which cost £950; the redeemable shares were redeemed at par. Q Ltd will realise a chargeable gain of £50. (The no gain/no loss provisions do not apply to this redemption).

  1. Ìý

    (c)ÌýÌýÌýÌý a disposal before 6 April 2019 of a high value (ie in excess of £1m from 1 April 2015 (or £2m before 1 April 2015, or

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