CG57402 - Non-resident companies: non-resident group: Reliefs for: non-resident groups

TCGA92/S14* gives relief from the TCGA92/S13* charge by allowing the provisions of TCGA92/S171, TCGA92/S174 and TCGA92/S175 (1) and, from 1 April 2000, TCGA92/S173 and TCGA92/S41 (8), to apply to non-resident groups, see CG57400. In particular this means

• transfers between members of the non-resident group are deemed to be for no gain/no loss, Section 171(1), But no gain/no loss treatment would not apply to any transfer between a member of the non-resident group and a UK resident company
• it is possible to claim roll-over relief against gains made by other members of the non-resident group, Section 175(1). See CG45930+ for general instructions on Section175.

* TCGA92/S13 was re-written for disposals from 6th of April 2019 see CG10150.