Taxation of Chargeable Gains Act 1992 section 174

Disposal or acquisition outside a group

Section 174 deals with how the 6 April 1965 time-apportionment rule applies when assets are transferred between companies within a group and then disposed of outside the group.

• When a company disposes of an asset it originally acquired from another group member under a no-gain/no-loss intra-group transfer, special rules apply for assets held on 6 April 1965.
• All members of the group are treated as if they were the same person for the purposes of the Schedule 2 time-apportionment rules.
• The original acquisition of the asset by the group is treated as if it were the acquisition by the company that ultimately disposes of the asset.
• This ensures that the period of ownership across successive group members is combined when calculating the time-apportioned gain or loss on disposal.