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HMRC internal manual

Capital Gains Manual

Assets disposed of: series of transactions: groups of companies

TCGA92/S20 (6) & TCGA92/S20 (7)

To prevent the exploitation of the rules in CG14680 where the provisions apply to a disposal which is not an ‘intra-group’ transfer

  • the first bullet of CG14680 does not apply to acquisitions from fellow group members and
  • for the purposes of the second bullet of CG14680, any disposal by way of an intra-group transfer before the first transaction in the series of linked transactions is assumed to have been made after that transaction.