Finance Bill provisions on degrouping charges

The current Finance Bill contains legislation intended to simplify the rules on corporate capital gains degrouping charges. These concern a change to where the degrouping charge arises; changes to the SSE rules; a new ‘just and reasonable’ test; and changes to the associated companies' exception. On the whole, these measures are welcome changes for groups involved in M&A activity as well as group reorganisations such as demergers and should have a positive impact in practice for them. The application of SSE and the extension of the SSE rules to enable the exemption to apply to divisional arrangements will simplify the issues that need to be addressed on many transactions.