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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Groups: rebasing: elections out of kink test: company takeovers

When one group takes over another the implications for elections out of the kink test depend on whether the takeover occurs before or after the relevant time in relation to the acquiring group. These instructions discuss the rules applying to company takeovers in terms of the following example. There is a target group headed by T which has various subsidiaries T1, T2 and so on. The predator group headed by P has subsidiaries P1, P2 and so on. P acquires all the shares in T. On the takeover, all the members of the T group become members of the P group. The instructions deal separately with the following two cases.

  • P acquires T before the relevant time for the P group, see CG46391.
  • P acquires T after the relevant time for the P group, see CG46392.