If a members club owning its own building becomes a Scottish Charitable Incorporated Organisation ( SCIO) or CIO in England is there a taxable gain on the property transferred?
Members club is an unincorporated association but is subject to corporation tax as it is within the definition of a "company" at s288 TCGA. The beneficial ownership of the property under the club constitution belongs the members equally. There is a no gain no loss treatment for gifts to a charity at s257 TCGA 1992 but does that apply here if not an individual and the club is subject to corporation tax on any gains?
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