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Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.3 Intra-group reorganisations /Intra-group transfers of capital assets / D6.305 Transfers of capital assets within a capital gains group—overview
Commentary

D6.305 Transfers of capital assets within a capital gains group—overview

Corporate tax

D6.305 Transfers of capital assets within a capital gains group—overview

Usually, the transfer of any chargeable assets between members of a chargeable gains group is made on a no gain/no loss basis for capital gains purposes1.

However, this rule is disapplied for a share exchange that is treated as

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