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Property transfer
How to value property transferred within a group.
I am looking at a capital gains tax issue where colleagues have differing views. The issue is the interaction of TCGA 1992 s 171 (intra-group transfers at no gain/no loss) and TCGA 1992 Sch 4AA para 7 (2015 rebasing).
My client has a property which will be transferred within a group. Does the transferee company acquire the property with a value rebased to April 2015 or does it simply take over the original base cost? When rebasing to March 1982 was introduced there was a rule (TCGA 1992 s 35(2)) which allowed the transferee to take over the transferor’s history and thus preserve rebasing but there does not seem to be a similar equivalent in these circumstances.
This particular matter has sent me around in circles and I wondered whether Taxation readers can help....
