One of the more interesting part of this year’s Finance Act from my perspective is that an anomaly that arose in FA 2011 has finally been fixed in FA 2019.
Following a review of the impact of capital gains on companies after the 2010 Budget FA 2011 changed the capital gains rules for degrouping of chargeable assets. Previously a transfer of an asset within a group followed by the disposal of the transferee company within six years triggered a capital gains tax charge as if that asset had been sold and reacquired by the transferee company. This operated unfairly in certain circumstances and one of the changes in FA 2011 was to ensure that the degrouping charge was instead treated as part of the proceeds for the disposal of the shares of the transferee company. This meant that if the disposal itself was...
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