Reorganisations

Question 1

Chargeable gains group

Answer 1

75%

Dormant companies excluded

Question 2

Ng/nl transfer

Answer 2

• if in same chargeable gains group then tax neutral transfer
• no gain or loss arises
• property deemed to be transferred at its original cost, this will be the base cost on any future disposals of the company
• these provisions are mandatory
• the market value and price paid at the time of the transfer is ignored

Question 3

Succession (trade transfer without change in ownership)

Answer 3

When UK company transferred from one company to another and they share 75% common ownership (at some point before and two years after the transfer)

Trading losses transferred to the new owner (restriction if net liabilities are left)

Capital allowance pools transferred at TWDV

For the first 5 years after succession, b/f losses incurred in the trade by the transferor May only be set against profits reasonably attributed to the carrying on of the transferred trade