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Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.3 Group capital gains /Group capital gains—transactions outside the group / D2.335 Group capital gains—claim for reduction of degrouping charge
Commentary

D2.335 Group capital gains—claim for reduction of degrouping charge

Corporate tax

A claim can be made for the adjustment of a degrouping charge in cases where it would be unreasonable for such a charge to apply1. These provisions apply where there is a gain that accrues either to the target company or to one or more vendor companies (ie where the alternative mechanism applies, see D2.333). The company to which the gain would accrue (either the vendor company or the target company) may make a claim for the gain to be reduced for all purposes by an amount that must be specified in the claim. Where a claim is made, HMRC is required to reduce the gain by such an amount as is

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