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HMRC internal manual

Capital Gains Manual

Capital distributions: rights issue: no gain/no loss transfer


A transfer of rights nil paid between spouses, civil partners of each other or members of the same group of companies must be dealt with on a no gain/no loss basis. For further instructions on transfers between spouses or between civil partners see CG22200+ and intra-group transfers see CG45300+. It will be necessary to apportion the transferor’s allowable cost and indexation allowance to calculate the notional disposal proceeds which would give them no gain/no loss.

NOTE. If a taxpayer is within the charge to Capital Gains Tax, neither indexation allowance nor taper relief apply to disposals of assets on or after 6 April 2008. Previously indexation allowance had been frozen at April 1998. Companies and other concerns within the charge to Corporation Tax are not affected by these changes. For indexation allowance see CG17207+ and for taper relief see CG17895+.