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Capital Gains Relief

 
Concluding our series on capital gains relief Hilary Barclay Solicitor Corporate Tax Group Macfarlanes LLP discusses the no gain no loss basis for intra-group disposals and related provisions
 
Although the number of third party transactions may have decreased recently intra-group transactions are still going strong. The relief provided by the Taxation of Chargeable Gains Act 1992 (TCGA 1992) s 171 which deems certain intra-group asset transfers to take place for a consideration which would give rise to neither a gain nor a loss is a helpful tool. But is it doing enough?
Getting territorial
 
Broadly speaking chargeable gains groups comprise a principal company and its 75%...

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