Degrouping charges and elections ― IFAs

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

Where a company ceases to be a member of the group, there is a deemed disposal and re-acquisition at market value of any intangible fixed assets owned by the company which were transferred to it by another group member within the six years prior to the date of the company ceasing to be a member of the group.

The deemed disposal and re-acquisition is treated as having taken place immediately after the original transfer of the relevant asset to the company leaving the group. The gain on the deemed disposal will be adjusted to reflect the difference between the amortisation debits actually taken into account and those which would have been taken into account if the asset had in fact been acquired at market value.

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