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Capital gains groups

Tax Planning: 2023/24

Edited by:
Mark McLaughlin
Publisher:
Bloomsbury Professional
Edition:
2023/24 edition
Publication Date:
March 2024
Law Stated At:
22 February 2024
Chapter 7: Groups and substantial shareholdings Qualifications for membership of a group Residence qualifications Transfer provisions Appropriations to or from trading stock Company ceasing to be a member of a group – capital gains rules Degrouping in reorganisations and reconstructions Claim for ‘just and reasonable’ adjustments: TCGA 1992, s 179ZA Merger exemption: TCGA 1992, s 181 Principal company becomes a member of another group: TCGA 1992, s 179 (5) Degrouping as a result of an exempt distribution demerger: TCGA 1992, s 192 (3) Notional transfers prior to a sale: TCGA 1992, s 171A ...

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