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United Kingdom
United Kingdom
Key definition
Capital gain definition What does Capital gain mean? Capital gain describes the profit realised when an asset is disposed of for more than its acquisition or base cost, after deducting allowable costs (for example, incidental acquisition and disposal expenses and qualifying enhancement expenditure). It arises on a disposal, not merely from an increase in value; an unrealised capital gain is a paper gain that would crystallise only if a disposal occurs. The opposite outcome is a capital loss. In practice, disposals include sales, gifts, part disposals and certain reorganisations. The concept is used across transactional, private client and corporate tax work because the timing, valuation and structure...
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Corporate capital gains degrouping (UK): TCGA 1992 s 179—anti-avoidance, SSE interaction, share disposals/reconstructions, subgroup exceptions, just and reasonable reductions, reallocation, takeovers, mergers/demergers, liquidation, non-residents
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Practice notes
Capital gains—intra-group asset transfers
Companies within a single capital gains group can shift assets among themselves without incurring corporation tax on chargeable gains (CGT), see Practice Note: Capital gains—intra-group asset transfers. To stop groups exploiting these reliefs to sidestep tax when disposing of assets that would otherwise trigger a substantial CGT charge, anti-avoidance rules are necessary. Rather than selling the asset outright, a group could pass it internally—probably to a company formed specifically for that purpose—and then dispose of the shares in that company. This device is commonly called the envelope trick and is outlined in more detail below. The statutory rules that block use of the envelope trick are the degrouping rules, set out in section 179 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992). The capital gains degrouping provisions can apply even where no avoidance is intended in practice. There is a possibility they may operate without the relevant companies being aware (until after the transaction). This is especially the case because the rules can take effect up to six years after an intra-group transfer has occurred (see below), often long after the event...
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Web page updated on 21/05/2026
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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...
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