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HMRC internal manual

Capital Gains Manual

Administration: insolvency: groups of companies


The commencement of the winding up of a company is not an occasion on which a companyceases to be a member of a group of companies, TCGA92/S170 (11). When assets aredistributed in kind within a group of companies as defined by TCGA92/S170 there is nochargeable gain or allowable loss on the assets themselves. However, the third bullet atCG40431 remains applicable as regards the deemed disposal of shares in the company,Innocent v Whaddon Estates Ltd 55TC476.

Where the disposal of shares in a member of a group of companies gives rise to a loss, theinstructions concerning depreciatory transactions at CG46500+ should be considered.