Degrouping Charges

The Finance Bill 2011 includes changes to the degrouping charge rules in s179, Taxation of Chargeable Gains Act 1992. The changes were originally anticipated to apply where a company leaves a group on or after the day the Bill receives Royal Assent. However, a government amendment to the Bill was introduced so that a group may elect that the new rules apply where a company leaves the group on or after 1 April 2011. The earlier commencement date will apply where the principal company of the capital gains group makes an election. The election must be made to HM Revenue & Customs and may be made until 31 March 2012.