½Û×ÓÊÓƵ

A degrouping charge is triggered if, within six years of an intra-group transfer, the transferee company leaves the group owning the asset (other than as trading stock) which it had acquired through the intra-group transfer¹.

For this purpose, a company is also treated as owning an asset if it²:

1. Ìý

   •ÌýÌýÌýÌý is owned by another company which leaves the group at the same time and the two companies would together form a separate group (see D2.331)

2. Ìý

   •ÌýÌýÌýÌý is property to which a chargeable gain has been rolled over on a replacement of business assets (see C3.302B), or

3. Ìý

   •ÌýÌýÌýÌý derives wholly or partly from the asset acquired on a no gain/no loss transaction; in particular, where the asset acquired is a lease and the company subsequently acquires the freehold reversion³

Where these provisions apply, the transferee company is treated as having sold and immediately reacquired the asset at market value immediately after its actual acquisition⁴.

The gain so calculated is treated differently