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HMRC internal manual

Capital Gains Manual

Non-resident companies: non-resident group: Reliefs for: non-resident groups

TCGA92/S14 gives relief from the TCGA92/S13 charge by allowing the provisions of TCGA92/S171, TCGA92/S174 and TCGA92/S175 (1) and, from 1 April 2000, TCGA92/S173 and TCGA92/S41 (8),to apply to non-resident groups, see CG57401. In particular this means

  • transfers between members of the non-resident group are deemed to be for no gain/no loss, Section 171(1), But no gain/no loss treatment would not apply to any transfer between a member of the non-resident group and a UK resident company
  • it is possible to claim roll-over relief against gains made by other members of the non-resident group, Section 175(1). See CG45930+ for general instructions on Section175.