171 Transfers within a group: general provisions

Transactions within groups

171  Transfers within a group: general provisions

[(1)     Where—

(a)     a company (“company A”) disposes of an asset to another company (“company B”) at a time when both companies are members of the same group, and

(b)     the conditions in subsection (1A) below are met,

company A and company B are treated for the purposes of corporation tax on chargeable gains as if the asset were acquired by company B for a consideration of such amount as would secure that neither a gain nor a loss would accrue to company A on the disposal.

(1A)     The conditions referred to in subsection (1)(b) above are—

(a)     that company A is resident in the United Kingdom at the time of the disposal, or the asset is a chargeable asset in relation to that company immediately before that time, and

(b)     that company B is resident in the United Kingdom at the time of the disposal, or the asset is a chargeable asset in relation

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