The loss and gain buying rules that prevent groups of companies from bringing together losses and gains which did not accumulate within the same group will be aligned with the major changes. They will focus on companies joining the worldwide group and assets falling within the UK tax net. These rules will commence on Budget day. There are a number of other consequential changes which carry over this change of approach. Background notes 1.
Companies can transfer assets on a tax neutral basis in a number of circumstances.
Intra group transfers 2. These rules have allowed a group to bring together gains and losses in a single company. Membership of a group is presently restricted to companies resident in the UK and to benefit from these rules multinational companies need to have a structure that concentrates their UK companies under a single UK resident company, regardless of whether that is the best commercial arrangement. The changes to the rules will mean that the country of residence no longer matters when identifying a group of companies and assets may now be transferred within the worldwide group on a tax neutral basis if the assets stay within the charge to UK corporation tax on chargeable gains. Schemes of reconstruction or amalgamation 6.