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HMRC internal manual

Capital Gains Manual

Groups: business asset roll-over relief: asset owned by non-trading company

TCGA92/S175 (2B)

A non-trading group company is treated as a trading company in relation to assets which it owns and which are used for trade purposes by trading companies in the same group.


Group parent company A, which did not itself trade, owned an asset used for trade purposes by company B in the same group. Company A sold the asset and replaced it with another which was also used by company B for trade purposes. Roll-over relief is available if the other conditions for relief are met.