Published on 14 Oct 10
by NATIONAL DIVISION, THE TAX INSTITUTE
This paper covers:
- interaction of the demerger rules with the tax consolidation regime
- no demerger relief for CGT event L5
- head company as a "demerging entity"?
- cost setting anomoly
- CGT straddle contracts - intra-group dealings
- straddle contract between group members
- straddle contract over an intra-group interest.
Current at 15 June 2011
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