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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Group share exchanges: Westcott v Woolcombers Ltd

60TC575The provisions giving roll-over treatment on share exchanges and other reorganisations, and the associated anti-avoidance test, apply both to group and non-group transactions. In the group context you also have to take account of the general no gain/no loss rule for transfers of assets in TCGA92/S171 (1).