D6.515 Common issues with international intra-group reconstructions/transfers
In addition to the rules detailed in Division D6.3, the following tax issues are usually associated with intra-group reconstructions/transfers involving non-UK companies.
International reorganisations—capital gains
Where a UK resident company transfers assets and/or shares in a non-resident subsidiary it will be liable to tax on any chargeable gains realised1 (see Division C1.1).
Similarly, where a non-UK resident company trading in the UK through a permanent establishment transfers assets and/or shares used in or for the purposes of a trade carried on in the UK through a permanent establishment2 it will be subject to tax on chargeable gains realised.
For both scenarios the computation of the gain differs depending upon whether the transfer is within a capital gains group or not:
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(a)ÌýÌýÌýÌý if the transfer is made within a capital gains group and the asset is within
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