Corporation tax – TCGA 1992 s171 – cross-border intragroup transfers

A recent First tier Tribunal (FTT) decision in the case of Gallaher Limited has decided that the nil gain/nil loss treatment under TCGA s171 should apply to a transfer of shares from a UK group company to a Dutch group...

Can UK nil/gain nil loss taxation of intragroup transfers (normally only available for asset transfers within the UK), apply to cross border transfers?

A recent First tier Tribunal (FTT) decision in the case of Gallaher Limited has decided that TCGA s171 should apply to a transfer of shares from a UK group company to a Dutch group company – without any requirement for...