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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 / D2.330 Group capital gains—degrouping charge trigger and degrouping charge calculation
Commentary

D2.330 Group capital gains—degrouping charge trigger and degrouping charge calculation

Corporate tax

A degrouping charge is triggered when a company leaves a group holding an asset (that is within the scope of UK tax on capital gains) which it acquired within the previous six years by way of an intra-group transfer made at a time when both companies concerned were members of the same group1.

This charge is calculated by deeming the company to have disposed of and reacquired the asset at its market value at the time of the original intra-group transfer2. The rules described at D2.325–D2.329 (computation, indexation etc) apply equally when calculating the degrouping gain or loss.

There are differing rules as to the

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