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HMRC internal manual

Capital Gains Manual

Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015: Companies: Special rules: Pooling of NRCGT gains and losses

It has long been a principle of the system for charging capital gains that companies within a group may transfer assets between themselves on a tax neutral basis.  They are allowed in effect to pool the assets of the group for tax purposes and pool gains and losses arising.


The CT legislation contains extensive provisions on groups of companies and pooling.  These aim to ensure that pooling arrangements should only be available to companies that comply with their obligations and provide us with clear information.  TCGA92/S188A to 188K build on this long established principle, by allowing non-resident companies which are part of a group to elect to pool losses and gains arising from the disposal of UK residential property.