Degrouping charge meaning

Currys Retail Ltd v HMRC [2025] UKFTT 762 (TC) Between 2004 and 2007, the taxpayer—previously named The Carphone Warehouse Ltd (CPW)—took over the businesses (the Businesses) together with the associated goodwill (Goodwill) of four companies operating within the same chargeable gains group. Although the aggregate value of the Goodwill was around £108m, TCGA 1992, s 171 applied so that these transfers did not trigger a tax charge. In 2008, as part of a joint venture arrangement with the Best Buy group, CPW exited membership of the chargeable gains group. Where a company departs a chargeable gains group holding an asset (other than a trading asset) that it acquired from another company in that group within the previous six years, TCGA 1992, s 179(3) treats the company as having disposed of, and immediately reacquired, that asset at the market value prevailing at the time of the intra‑group acquisition. By 2008, however, the value of the Goodwill had fallen to about £50.8m. Consequently, the degrouping charge would result in CPW becoming...

This Practice Note explains the two chargeable gains tax reliefs relevant to dealings under a scheme of reconstruction. For a definition of ‘scheme of reconstruction’, refer to the Practice Note: Schemes of reconstruction defined...

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: In 2027, stamp duty and SDRT are set to give way to a unified, self-assessed levy on securities—the securities transfer charge (STC)—to be paid and reported through a new digital portal. In broad terms, the STC’s design will align with the proposals for that tax set out in the 2023 consultation. Finance Bill 2026 (FB 2026) creates a power, commencing on Royal Assent, for secondary legislation that will enable taxpayers to pilot the digital service by self-assessing their stamp taxes on securities obligations and submitting transactions electronically via the service. This will allow reporting and payment to be handled online as part of the modernisation of stamp taxes on shares. For detailed coverage of the modernisation of stamp taxes on securities, see: News Analyses: Budget 2025—Tax analysis—Stamp and transfer taxes Tax update spring 2025—Stamp taxes on shares modernisation Tax update spring 2025—Tax analysis—Stamp and transfer taxes TAMD 2023—Stamp taxes on...

This Practice Note examines the UK tax implications of forming a joint venture structured as a limited liability company (JVCo), which is a distinct legal person from the joint venture parties. In particular, it covers: reasons a corporate joint venture vehicle is often selected tax charges arising for a joint venture party on transferring assets to a JVCo tax charges that fall on the JVCo when assets are transferred to it further points where the JVCo is, or later becomes, within the group of one joint venture party, and availability of merger relief when subsidiaries are moved into the JVCo For commentary on the tax aspects of running and winding up joint ventures using a JVCo, see Practice Note: Tax implications of operating and terminating a joint venture company. For the purposes of this Practice Note, it is assumed the joint venture parties are UK tax resident corporate entities and that the JVCo is UK tax resident (for information...

[ Letterhead ] [ Addressed to HMRC Officer ] [ Date ] We jointly make an election under section 792 of the Corporation Tax Act 2009 (CTA 2009) that [ the whole OR [ insert a specific amount, a percentage or a fraction ] ] of the chargeable realisation gain arising on the deemed realisation and reacquisition of the intangible assets is to be regarded as attributable to [ full company name ] (Company B) rather than [ full company name ] (Company A)...