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HMRC internal manual

Capital Gains Manual

Groups: rebasing: no gain/no loss disposals after 31/3/82

For the purposes of this rule a no gain/no loss disposal is a disposal under any of the capital gains provisions giving no gain/no loss treatment listed in TCGA92/S35 (3)(d). The list includes

  • TCGA92/S139 (transfer of business on reconstruction or amalgamation, see CG52800+)
  • TCGA92/S171 (1) (intra-group asset transfers, see CG45305+)
  • TCGA92/S172 (inward domestication within a worldwide group.

Company A acquires an asset in 1981 and transfers the asset to group company B in 1985 at no gain/no loss under Section 171(1). Company B disposes of the asset to an unconnected third party in 1992. For rebasing purposes company B is treated as having held the asset on 31 March 1982.