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Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.3 Group capital gains /Group capital gains—transactions outside the group / D2.327 Group capital gains—assets held at 31 March 1982
Commentary

D2.327 Group capital gains—assets held at 31 March 1982

Corporate tax

Where a company disposes of an asset outside the group which it held on 31 March 1982 and which has already been subject to an intra-group transfer, special provisions apply for:

  1. Ìý

    •ÌýÌýÌýÌý the purposes of computing the indexation allowance, and

  2. Ìý

    •ÌýÌýÌýÌý the general rebasing provisions

For both these purposes, specific provisions also apply for the 31 March 1982 valuation of shares (see below).

Indexation allowance

For the purposes of computing the indexation allowance:

  1. Ìý

    •ÌýÌýÌýÌý the company making the disposal outside the group is treated as having held the asset at 31 March 1982. The indexation allowance is therefore calculated on the 31 March 1982 value for the period from 31 March 1982 to December 2017 (or the date of disposal, if earlier; see C2.301) (unless it would be greater if computed by reference to the company's deemed acquisition cost and no automatic rebasing election has been made1). However, to prevent a double indexation allowance being given, the base cost to the disposing company (following the latest intra-group

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