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The degrouping charge is not triggered when:

1. Ìý

   •ÌýÌýÌýÌý the company holding the relevant asset ceases to be a member of a group as a result of its only subsidiary leaving the group (the 'two company group practice')¹

2. Ìý

   •ÌýÌýÌýÌý a company leaves the group in consequence of another company in the group ceasing to exist (the 'liquidation let-out'). HMRC consider that the only situation where this exclusion applies is where a parent company ceases to be a member of a group on the occasion of its only subsidiary ceasing to exist on dissolution (or all its subsidiaries ceasing to exist simultaneously on dissolution)². The commencement of a winding up does not break the group relationship, and HMRC take the view that a company does not cease to exist until actual dissolution, ie three months after registration of the liquidator's final return³

3. Ìý

   •ÌýÌýÌýÌý the transferee and transferor leave the group at the same time and the two companies would together form a separate group (the 'sub-group exemption',