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HMRC internal manual

Capital Gains Manual


TCGA92/S192 (3)

In broad terms there is a demerger where trading activities carried on by a single company or group of companies are divided so as to be carried on by two or more independent companies or groups. There are special tax rules for demergers which fall within the scope of ICTA88/S213, see CT1725-CT1731. In particular TCGA92/S192 (3) disapplies the capital gains degrouping charge in TCGA92/S178 and TCGA92/S179, see CG45400+ where a company ceases to be a member of a group by reason only of an exempt distribution within ICTA88/S213 (2).