Clause 77 - De-grouping charge: transitional relief
Finance Bill
10:00 am
Mr Howard Flight (Arundel and South Downs, Conservative)
The clause covers fairly complex territory and its provisions are, in the main, welcome. I have had some difficulty in understanding the technical note about subsection (6). What are the circumstances in which a section 179 charge will arise when a company holding a previously transferred asset leaves a worldwide group less than six years after the transfer of the asset within an old UK-only capital gains tax group?