Continuing the series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) explain the rules for capital gains groups and the pitfalls to watch out for in practice.
The rules governing capital gains groups enable a streamlined approach within a group for dealing with chargeable assets. The primary benefit is that chargeable assets can be transferred between group companies without triggering a taxable gain (or loss). This treatment applies automatically without requiring an election thereby minimising the administrative and cash tax burden as regards internal asset transfers.
Additionally under TCGA 1992 s 171A group companies can elect to transfer all or part of a chargeable gain or allowable loss for the current year among themselves enabling tax-efficient utilisation of group tax attributes (for example tax losses). Also TCGA 1992 s 152 provides that rollover relief treats the group as a single...
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Continuing the series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) explain the rules for capital gains groups and the pitfalls to watch out for in practice.
The rules governing capital gains groups enable a streamlined approach within a group for dealing with chargeable assets. The primary benefit is that chargeable assets can be transferred between group companies without triggering a taxable gain (or loss). This treatment applies automatically without requiring an election thereby minimising the administrative and cash tax burden as regards internal asset transfers.
Additionally under TCGA 1992 s 171A group companies can elect to transfer all or part of a chargeable gain or allowable loss for the current year among themselves enabling tax-efficient utilisation of group tax attributes (for example tax losses). Also TCGA 1992 s 152 provides that rollover relief treats the group as a single...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
