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HMRC internal manual

Capital Gains Manual

Share identification rules for corporation tax: section 104 holding: no gain/loss transfers 30/11/93p

The commonest type of no gain/no loss transfer for corporation tax is a disposal between members of the same group of companies, TCGA92/S171. Where such an transfer is made on or after 30 November 1993 indexation is added only to the pool of indexed expenditure. For transfers made before that date indexation was added to both the pool of qualifying expenditure and the pool of indexed expenditure for the transferee company.