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HMRC internal manual

Capital Gains Manual

Non-resident companies: non-resident group: degrouping charges

TCGA92/S14 (3)

The anti-avoidance provisions of TCGA92/S178 and TCGA92/S179 apply to non-resident groups. There will be a charge under TCGA92/S13 if a company leaves the `non-resident group’ holding an asset acquired from another group member within the previous six years. For general guidance on Sections 178 and 179, see CG45400+.