Howard Murray and Sara Stewart take a look at the main tax issues as well as any other particular issues arising from pre-sale hive-downs and debt reorganisations.
The tax position for simple intra-group transfers is detailed below.
Corporation tax on chargeable gains and intangibles: The transfer of capital assets (such as shares in a group company and property assets) will be on a no gain/no loss basis if within a chargeable gains group under TCGA 1992 s 171. If the transfer is not within a chargeable gains group it is likely that the connected party rules will apply so that market value will be imputed (TCGA 1992 s 18). This may lead to a tax charge for the transferee. It may be though that the group has access...
