D6.301 Intra-Group Reorganisations—Overview

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Commentary

Corporate tax

For updates affecting this Division please see Part D0 Updates

Intra-group reorganisations—scope

D6.301 Intra-group reorganisations—overview

This Division details the tax implications arising from an intra-group transfer/reorganisation of individual chargeable assets or

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E5.607 Corporate members

B3.325 General exclusions—first-year qualifying expenditure

I9.421 Situs of simple contract debts for IHT

I4.142A Liabilities which are not discharged out of the estate

B4.130 Summary of OECD guidelines on arm's length principle

I3.367 Fall in value relief—changes in interests in land

E6.303A Domicile of origin

A4.214 Claims following further assessments—income tax and capital gains tax

D7.1140 Methods of leaving the REIT regime

B5.123 BPS—negligible value claims

C1.213 Liability to tax on chargeable gains—trustees in bankruptcy

E8.271 Liability for Class 1A contributions

I4.562 Sales and mortgages of reversionary interests

B2.315 The concept of wholly and exclusively

C3.304 Rollover relief—expenditure on replacement assets qualifying for relief

C2.108 Contingent liabilities

I5.221 Lifetime termination of QIIP—general

C3.1713 PPR relief where a dependent relative occupied the residence prior to 6 April 1988

B2.202 Capital receipts

D4.104 Company residence and the case law test

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D6.301 Intra-group reorganisations—overview

Corporate tax

Intra-group reorganisations—scope

D6.301 Intra-group reorganisations—overview

E5.607 Corporate members

B3.325 General exclusions—first-year qualifying expenditure

I9.421 Situs of simple contract debts for IHT

I4.142A Liabilities which are not discharged out of the estate

B4.130 Summary of OECD guidelines on arm's length principle

I3.367 Fall in value relief—changes in interests in land

E6.303A Domicile of origin

A4.214 Claims following further assessments—income tax and capital gains tax

D7.1140 Methods of leaving the REIT regime

B5.123 BPS—negligible value claims

C1.213 Liability to tax on chargeable gains—trustees in bankruptcy

E8.271 Liability for Class 1A contributions

I4.562 Sales and mortgages of reversionary interests

B2.315 The concept of wholly and exclusively

C3.304 Rollover relief—expenditure on replacement assets qualifying for relief

C2.108 Contingent liabilities

I5.221 Lifetime termination of QIIP—general

C3.1713 PPR relief where a dependent relative occupied the residence prior to 6 April 1988

B2.202 Capital receipts

D4.104 Company residence and the case law test

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D6.301 Intra-group reorganisations—overview

Corporate tax

Intra-group reorganisations—scope

D6.301 Intra-group reorganisations—overview

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POLICIES

EXAM TRAINING

RESEARCH AND GUIDANCE

PROFESSIONAL DEVELOPMENT