Chapter CG45135

Published date12 March 2016
Record NumberCG45135
CourtHM Revenue & Customs
IssuerHM Revenue & Customs
TCGA92/S170 (11)

The commencement of the winding-up of a company does not break group relationships for capital gains purposes. When winding-up commences a company loses its beneficial interest in its assets, including shares owned in other companies (Ayerst v C & K (Construction) Ltd 50TC651) and without this rule the commencement of winding-up of an intermediate holding company within a capital gains group would lead to that company’s own subsidiaries leaving the group.

The passing of a resolution or the making of an order, or any other act, for the winding-up of a group member is not regarded as the occasion of that or any other company ceasing to be a member of the...

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