Taxation of Chargeable Gains Act 1992 Schedule 7A paragraph 12

Companies changing groups on certain transfers of shares etc.

Paragraph 12 deals with what happens to a company's pre-existing capital losses and assets when it moves from one corporate group to another as a result of a no gain/no loss share disposal.

• When a company moves from one group to another because of a disposal of shares or securities, and that disposal is a no gain/no loss transaction, the change of group does not trigger any restriction on the company's earlier losses.
• The company's time as a member of the old group is treated as if it were part of the period during which the company was a member of the new group.
• This preserves continuity for the company's pre-existing capital losses and the assets it held at the time of the group change.
• This rule operates alongside the broader continuity provisions in paragraph 11 of Schedule 7A, providing an additional safeguard for no gain/no loss transfers.