Degrouping Charges and IFAs

by **anon123** on Mon Nov 23, 2009 6:54 pm

The transfer of an asset between members of a 75% group is on a no gain no loss basis. Under S179 TCGA 1992 there is a degrouping charge if the recipient company leaves the group within 6 years and still owns the asset at that time. Similar provisions, based on the CG rules, apply to an intra group transfer of an intangible fixed asset.

HMRC confirms at CG45450 that it does not apply the degrouping charge where the company receiving the asset ceases to be a group member as a result of its only subsidiary leaving the group. Would this 'exemption' also cover potential degrouping charges on the transfer of IFA or would this be a step too far?

by **Incredulum** on Thu Dec 03, 2009 6:30 pm

What is IFA?

by **Incredulum** on Thu Dec 03, 2009 6:32 pm

Sorry, now I see.

What rules, other than s179, apply to an IFA, and why does 179 not apply to an IFA?

179 applies to "an asset" and makes no reference to its tangible status.