As mentioned in CG45000, the capital gains rules that affect groups of companies have changed considerably over the years. This ‘potted history’ outlines the main changes:

1965 – Introduction of CGT, applying to companies

Recognition of a group as an economic entity with no triggering of gains and losses on transfers within the group. Also, the share exchange provisions mean that gains and losses may not be triggered immediately when shares (or securities) are exchanged for others.

The group definition, TCGA92/S170, CG45100+; nil gain/nil loss disposals within the group, TCGA92/S171, CG45300+; the share reorganisation rules, TCGA92/S127, S135 etc…, CG51700+.

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