TCGA92/S171(2) and TCGA92/S101A

Section 171 TCGA 1992 allows companies which are members of the same group to transfer assets to one another at a tax value that gives rise to neither a gain nor a loss. But section 171(2)(c) TCGA 1992 prevents that rule from applying where the transfer is to or by a company that is an approved investment trust. This is because gains made by an approved investment trust are not chargeable gains.

If the section 171 TCGA 1992 no gain/no loss transfer is made to a company that, at the time of the transfer, was not an approved investment trust, but:

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