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Degrouping charge definition

What does Degrouping charge mean? A degrouping charge is a corporation tax/capital gains tax charge that claws back no gain/no loss treatment on an intra‑group asset transfer when a company leaves a group still holding that asset. It is set out in legislation (UK: TCGA 1992 for chargeable assets and parallel rules in CTA 2009 for intangible fixed assets; Ireland: TCA 1997). UK: A charge arises if the company leaves the group within six years of acquiring the asset from another group member. The amount is computed as the gain or loss that would have arisen had the company sold and immediately reacquired the asset...

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Joint election letter to HMRC under CTA 2009 s 792: reallocating intangible fixed assets degrouping charge to another group company

Published by a LexisNexis Tax expert
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[ 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)...

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Web page updated on 22/05/2026

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